Comment from Nationwide Mutual Insurance Company

Summary: Nationwide Mutual Insurance Company supports the proposed regulations but argues that they should include a specific transition rule for pre-2023 nonlife net operating loss (NOL) carryforwards. They contend that without this adjustment to adjusted financial statement income (AFSI), the Corporate Alternative Minimum Tax (CAMT) would unfairly penalize taxpayers for taxes effectively prepaid before the CAMT was in effect.