Comment from American Property Casualty Insurance Association

Summary: The American Property Casualty Insurance Association (APCIA), National Association of Mutual Insurance Companies (NAMIC), and Reinsurance Association of America (RAA) oppose the proposed calculation of the Corporate Alternative Minimum Tax (CAMT) as it currently stands. They argue that including net operating loss (NOL) carrybacks in the CAMT calculation creates a mismatch with regular tax treatment, effectively erasing the capital access benefits granted to property casualty insurers by the Tax Cuts and Jobs Act.