Comment from Global Business Alliance

Summary: The Global Business Alliance (GBA), representing nearly 200 international companies, opposes several aspects of the proposed Corporate Alternative Minimum Tax (CAMT) regulations. They argue that the proposed "top-down" approach for determining adjusted financial statement income (AFSI) is impractical and distortive, and they advocate for a "bottom-up" approach using domestic reporting packages. Additionally, they request the removal of certain reporting requirements, the exclusion of regular tax restrictions on foreign tax credits, and modifications to rules regarding partnership contributions and net operating losses.