Comment from Novo Nordisk Inc.

Summary: Novo Nordisk Inc. opposes several provisions of the proposed Corporate Alternative Minimum Tax (CAMT) regulations, arguing they create excessive administrative burdens and unfavorable tax consequences. Specifically, the company advocates for a "fresh start" transition approach, a "bottom-up" method for determining financial statement income for domestic subsidiaries, and the ability to use tax attributes from acquisitions to offset CAMT liability.