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What Limitations Apply to the CAMT Foreign Tax Credit?

International Tax Journal

In this article, Layla Asali, Caroline Reaves, and Candice James consider the scope of the Corporate Alternative Minimum Tax (CAMT) foreign tax credit of Code Sec. 59(l) and the extent to which the many limitations and restrictions that apply to the foreign tax credit in the regular tax system apply, or should apply, to the CAMT foreign tax credit. While there are some elements of the regular foreign tax credit that clearly should apply to the CAMT foreign tax credit and others that clearly should not, there are several provisions where the question presents a closer call. The authors assess each of these provisions and make recommendations based on the CAMT statute and its discernible policy objectives.