Press Release: 9/10/2025
Warren, King, Lawmakers Slam Treasury for Creating Loopholes In Corporate Alternative Minimum Tax
“These notices weaken CAMT under the cover of bureaucratic rulemaking and give the largest and wealthiest corporations yet another get-out-of-paying-taxes-free card.”
Washington, D.C. – U.S. Senators Elizabeth Warren (D-Mass.) and Angus King (I-Maine) led Senators John Hickenlooper (D-Colo.), Sheldon Whitehouse (D-R.I.), Ed Markey (D-Mass.), and Representative Don Beyer (D-Va.) in writing to Secretary of the Treasury Scott Bessent, slamming him on the Trump administration’s attempts to create new loopholes in the corporate alternative minimum tax (CAMT) for the largest and wealthiest corporations.
Prior to CAMT’s enactment, corporations worth billions of dollars would routinely pay little or no federal income tax. From 2018 to 2020, 39 Fortune 500 companies generating $122 billion in profit paid $0 in federal income tax. Congress passed the corporate alternative minimum tax as part of the Inflation Reduction Act to put an end to this scheme.
Recently, the Trump administration issued two new interim guidance notices intended to erode the CAMT.
“These notices will allow major corporations to circumvent the law by using accounting trickery to pay zero taxes on their massive profits,” wrote the senators.
One of these notices, Notice 2025-27, issued this June, allows companies to avoid CAMT if their income—under a simplified accounting method—is below $800 million. That threshold, changed with no explanation, is significantly higher than the Biden Administration's threshold of $500 million, allowing more wealthy corporations to escape CAMT liability. Further, this notice also indicates future potential erosion of the CAMT tax base by stating that Treasury and the IRS will reconsider the treatment of unrealized capital gains.
The other notice, Notice 2025-28, issued in July, creates additional complexity for tax administrators and risks enabling gaming and inconsistent outcomes across similarly situated taxpayers.
“These notices weaken CAMT under the cover of bureaucratic rulemaking and give the largest and wealthiest corporations yet another get-out-of-paying-taxes-free card,” continued the senators. “We are seriously concerned that this cursory loosening of CAMT enforcement will simply allow more wealthy corporations to avoid paying their legally owed share.”
The senators point out that CAMT is the law of the land and was left in place following the passage of the One Big Beautiful Bill Act, meaning the Administration is required to implement CAMT consistent with Congressional intent.
“We urge the IRS to rescind Notice 2025-27 and Notice 2025-28 and finalize the Biden Administration’s proposed CAMT regulations without delay,” concluded the senators.