119-SJRES-95 Journalist Public Summary

Public Summary

Headline Summary: Congress would overturn the IRS’s interim guidance on how the 15% Corporate Alternative Minimum Tax (CAMT) applies to corporations’ partnership investments. [1]Congress.gov — S.J.Res.95 — Text as Introduced (Nov. 18, 2025)[2]IRS — IRS Notice 2025‑28 in Internal Revenue Bulletin 2025‑34 (Interim CAMT Gui…

What It Does: The resolution uses the Congressional Review Act (CRA) to nullify IRS Notice 2025‑28, which created temporary, simplified methods and reporting rules for calculating CAMT amounts tied to partnership income. If enacted, the notice would have no force or effect, and issuing a substantially similar rule could be barred absent new legislation. [1]Congress.gov — S.J.Res.95 — Text as Introduced (Nov. 18, 2025)[2]IRS — IRS Notice 2025‑28 in Internal Revenue Bulletin 2025‑34 (Interim CAMT Gui…[3]Congressional Research Service — CRS FAQ: The Congressional Review Act (R43992)

Why It Matters: CAMT generally imposes a 15% minimum tax on large corporations’ adjusted financial statement income (AFSI). The notice introduced elections (including a “Top‑Down” and, in some cases, a “Taxable‑Income” method) and eased partnership reporting to reduce compliance burden—changes welcomed by practitioners but viewed by some lawmakers as potentially undercutting a tougher CAMT. [2]IRS — IRS Notice 2025‑28 in Internal Revenue Bulletin 2025‑34 (Interim CAMT Gui…[5]KPMG — KPMG TaxNewsFlash: Notice 2025‑28 (CAMT—partnerships)[6]U.S. Senate Office of Angus King — King, Warren press release urging strong CAM…

• Who’s For It: • Sponsor — Sen. Ron Wyden (D‑OR) introduced the resolution on November 18, 2025. [1]Congress.gov — S.J.Res.95 — Text as Introduced (Nov. 18, 2025)
• Context for supporters’ view: Wyden has pushed for stronger enforcement on large partnerships and a robust CAMT, signaling concern that overly flexible guidance could weaken the law’s intent. (Inference based on prior statements; no specific statement on S.J. Res. 95 yet.) [7]U.S. Senate Finance Committee — Wyden Statement on IRS effort targeting large p…[6]U.S. Senate Office of Angus King — King, Warren press release urging strong CAM…

• Who’s Against It: • Tax and business practitioners have described the IRS notice as simplifying compliance and offering workable options, suggesting concern that repeal would restore complexity and uncertainty for current filings. (Analyst summaries, not formal positions on this resolution.) [8]PwC — PwC Insight: Interim guidance simplifies application of CAMT to partnersh…[5]KPMG — KPMG TaxNewsFlash: Notice 2025‑28 (CAMT—partnerships)[9]BDO USA — BDO: IRS aims to simplify CAMT guidance relating to partnership inter…

What’s Next: The measure has been read twice and referred to the Senate Finance Committee. Because the IRS sent Notice 2025‑28 to Congress under the CRA, the resolution can access expedited Senate procedures if time windows are met; to take effect it must pass both chambers and be signed by the President. [1]Congress.gov — S.J.Res.95 — Text as Introduced (Nov. 18, 2025)[4]Congress.gov — House Executive Communication EC2103 — IRS Notice 2025‑28 submit…[3]Congressional Research Service — CRS FAQ: The Congressional Review Act (R43992)

• Approximate number of companies subject to CAMT cited by some lawmakers: ~150. (Context for scale.) [6]U.S. Senate Office of Angus King — King, Warren press release urging strong CAM…