This panel will explore the impact of recent Treasury and IRS guidance on CAMT determinations, concentrating on guidance addressing an applicable corporation’s liability inclusion with respect to a partnership investment. The discussion will cover top-of-mind topics, including:

• An overview of the recent guidance from Treasury and IRS on CAMT;
• The potentially favorable but not-so-simple options available for applicable corporations who are partners and need to compute a distributive share of partnership AFSI; and
• Key considerations for applicable corporations engaged in partnership M&A activities.