Comment from Securities Industry and Financial Markets Association (SIFMA)

Summary: The Securities Industry and Financial Markets Association (SIFMA) supports the implementation of the Corporate Alternative Minimum Tax (CAMT) but argues that the Proposed Regulations introduce excessive complexity and compliance burdens. They advocate for several modifications, including a "top-down" election for partnership interests to simplify AFSI calculations and the ability to elect out of "deferred sale" provisions to align the tax with book income.