U. S. Business Income Tax Return

2024

Instructions for Form 4626
Alternative Minimum Tax—Corporations
Section references are to the Internal Revenue Code unless
otherwise noted.

Future Developments
For the latest information about developments related to
Form 4626 and its instructions, such as legislation enacted
after they were published, go to IRS.gov/Form4626.

What’s New
Pro-Rata Share of Adjusted Net Income or Loss of
CFCs. Schedule A (Form 4626), Pro-Rata Share of Adjusted
Net Income or Loss of CFCs Described in Section 56A(c)(3),
a separate schedule, (formerly Worksheet A) was developed.
See the Instructions for Schedule A.
New Part VI. Part VI—Aggregate Pro-Rata Share of
Adjusted Net Income or Loss of CFCs Described in Section
56A(c)(3) (formerly Worksheet B) was added to Form 4626.

General Instructions
Purpose of Form

Form 4626 is used to determine whether a corporation is an
applicable corporation under section 59(k) and to calculate
Corporate Alternative Minimum Tax (CAMT) under section 55
for applicable corporations.

Consolidated returns. For an affiliated group filing a
consolidated return under the rules of section 1501, CAMT is
calculated on a consolidated basis.

Who Must File

Unless a filing exclusion applies, a corporation must file Form
4626 to determine whether it is an applicable corporation
and, if it is classified as an applicable corporation, to
calculate CAMT.
Filing exclusions. A corporation is not required to file Form
4626 if the corporation is:
• An S corporation;
• A regulated investment company (RIC);
• A real estate investment trust (REIT);
• A tax-exempt entity that is not required to file an exempt
organization business income tax return because it has no
unrelated business taxable income (even if such entity is a
member of a controlled group treated as a single employer
under sections 59(k)(1)(D) and 52); or
• A corporation that is not required to file Form 4626
because it is not an applicable corporation under the
simplified method and chooses to apply that method. This
filing exception does not apply if the corporation is an
applicable corporation in the current tax year because the
corporation was an applicable corporation in a prior tax year.

When To File

Attach Form 4626 to the corporation’s income tax return (or, if
applicable, exempt organization business income tax return)
and file by the due date (including extensions) for that return.

Interim Guidance
Proposed Regulations—Proposed Applicability
Dates and Reliance Prior to Applicability

The Treasury Department and the IRS issued a Notice of
Proposed Rulemaking published in the Federal Register on
September 13, 2024. See 89 FR 75062, as corrected by 89
FR 104909. Until finalized, these proposed regulations are
non-binding and subject to change. Some sections of the
proposed regulations are proposed to apply to tax years
ending after September 13, 2024 (“specified proposed
regulations”). When final regulations are published in the
Federal Register, these sections would apply to tax years
ending after September 13, 2024. Other sections of the
proposed regulations are proposed to apply to tax years
ending after the date that final regulations are published in
the Federal Register (“other proposed regulations”).
Corporations would not be required to apply these sections of
the proposed regulations until final regulations are published
in the Federal Register. Special rules, discussed below, are
provided for corporations that choose to rely on sections of
the proposed regulations for tax years ending on or before
their proposed applicability dates.

Specified Proposed Regulations—Proposed
Applicability Date

The following sections of the proposed regulations apply to
tax years ending after, and, in certain cases, transfers (as
defined in Proposed Regulations section 1.56A-4(b)(3))
occurring after, September 13, 2024.
• Proposed Regulations sections 1.56A-1 through 1.56A-4.
• Proposed Regulations sections 1.56A-6 through 1.56A-11.
• Proposed Regulations section 1.56A-13.
• Proposed Regulations section 1.56A-14.
• Proposed Regulations section 1.56A-17.
• Proposed Regulations section 1.56A-26.
• Proposed Regulations section 1.56A-27.
• Proposed Regulations sections 1.59-2 through 1.59-4.

The provisions of Proposed Regulations sections
1.56A-5(l)(2)(ii) and (iii) apply to tax years ending after
September 13, 2024, and on or before the date of publication
of final regulations in the Federal Register, in order to
coordinate certain provisions of the specified proposed
regulations.

Reliance on Specified Proposed Regulations for
Tax Years Ending Before Proposed Applicability
Date
Corporations may rely on the specified proposed regulations
for any tax year ending on or before September 13, 2024,

Jan 29, 2025

Instructions for Form 4626 (2024) Catalog Number 64443L
Department of the Treasury Internal Revenue Service www.irs.gov

provided the corporation, and each member of its test group
determined under Proposed Regulations section 1.59-2 for
that tax year, consistently follows all of the specified
proposed regulations in their entirety in that tax year and
each subsequent tax year (taking into account any changes
to its test group determined under Proposed Regulations
section 1.59-2 for each subsequent tax year) until the first tax
year in which the final regulations are applicable and also
applies the rules described in Proposed Regulations sections
1.56A-4 and 1.56A-6 that apply to transfers (as defined in
Proposed Regulations section 1.56A-4(b)(3)) to any transfers
occurring in such years.

occurring in such years. Notwithstanding the prior sentence,
a corporation may not rely on Proposed Regulations sections
1.56A-18, 1.56A-19, and 1.56A-21 in any tax year unless the
corporation and each member of its test group determined
under Proposed Regulations section 1.59-2 for that tax year
rely on each of those sections in its entirety. In addition, a
corporation may not rely on Proposed Regulations sections
1.56A-5 (excluding Proposed Regulations sections 1.56A-5(l)
(2)(ii) and (iii)) and 1.56A-20 in any tax year unless the
corporation and each member of its test group determined
under Proposed Regulations section 1.59-2 for that tax year
rely on each of those sections in its entirety.

A corporation may rely on the rules described in Proposed
Regulations sections 1.56A-4 and 1.56A-6 that apply to
transfers for a transfer occurring on or before September 13,
2024, provided the corporation, and each member of its test
group determined under Proposed Regulations section
1.59-2 for the tax year of the corporation that includes the
date of the transfer, consistently follow all of the rules in
Proposed Regulations sections 1.56A-4 and 1.56A-6 for all
such transfers occurring on or before September 13, 2024,
during a tax year of the taxpayer and each subsequent tax
year until the final regulations are applicable to such
transfers, and if any such transfers occur in tax years ending
on or before September 13, 2024, must rely on the specified
proposed regulations for such tax years.

Reliance on Interim Notice Guidance

Other Proposed Regulations—Proposed
Applicability Dates

The following sections of the proposed regulations apply to
tax years ending after the date the final regulations are
published in the Federal Register.
• Proposed Regulations section 1.56A-5 (other than
sections 1.56A-5(l)(2)(ii) and (iii)).
• Proposed Regulations section 1.56A-12.
• Proposed Regulations section 1.56A-15.
• Proposed Regulations section 1.56A-16.
• Proposed Regulations sections 1.56A-18 through
1.56A-25.
The provisions of the following sections apply to
consolidated return years for which the due date of the
income tax return (without extensions) is after the date of
publication of final regulations in the Federal Register:
• Proposed Regulations section 1.1502-2.
• Proposed Regulations section 1.1502-53.
• Proposed Regulations section 1.1502-56A.

Reliance on Other Proposed Regulations for Tax
Years Ending Before Proposed Applicability
Date

Corporations may rely on one or more of the other proposed
regulations for any tax year ending on or before the date the
final regulations are published in the Federal Register
provided that, for each section on which the corporation
relies, the corporation, and each member of its test group
determined under Proposed Regulations section 1.59-2 for
that tax year, consistently follow that section in its entirety and
also follow all of the specified proposed regulations in their
entirety in that tax year and each subsequent tax year (taking
into account any changes to its test group determined under
Proposed Regulations section 1.59-2) until the first tax year
in which the final regulations are applicable and also applies
the rules described in Proposed Regulations sections
1.56A-4 and 1.56A-6 that apply to transfers (as defined in
Proposed Regulations section 1.56A-4(b)(3)) to any transfers

2

The Treasury Department and the IRS also issued interim
guidance published in the Internal Revenue Bulletin.
• Notice 2023-7, 2023-3 I.R.B. 390, available at IRS.gov/irb/
2023-03_IRB#NOT-2023-7.
• Notice 2023-20, 2023-10 I.R.B. 523, available at
IRS.gov/irb/2023-10_IRB#NOT-2023-20.
• Notice 2023-64, 2023-40 I.R.B. 974, available at
IRS.gov/irb/2023-40_IRB#NOT-2023-64.
• Notice 2024-10, 2024-03 I.R.B. 406, available at
IRS.gov/irb/2024-03_IRB#NOT-2024-10.
Corporations may be able to rely on some or all of the
interim guidance provided, subject to the following
applicability dates and reliance conditions for each of the
notices.
Except as provided in the next paragraph, pursuant to
Notice 2023-64, section 15.02, a corporation may rely on the
interim guidance provided in Notice 2023-7, sections 3
through 7, (as modified and clarified by Notice 2023-64),
Notice 2023-20, sections 3 through 5, and Notice 2023-64,
sections 3 through 14, for tax years ending on or before
September 13, 2024.
Pursuant to Notice 2024-10, section 5.01, corporations
may rely on the interim guidance provided in Notice 2024-10,
section 3, for covered CFC distributions (as defined in the
Notice) received on or before September 13, 2024. In
addition, pursuant to Notice 2024-10, section 5.02,
corporations may rely on the interim guidance provided in
Notice 2023-64, sections 4.02(5)(b) and 6.02 (as modified by
Notice 2024-10) and Notice 2024-10, section 4.04, for tax
years ending before September 13, 2024. A corporation may
not rely on the unmodified text of Notice 2023-64, sections
4.02(5)(b)(i) or 6.02, for any tax return filed on or after
December 15, 2023.

Statement of Rules Applied

Corporations must include with Form 4626 a statement
describing the approach taken in completing Form 4626 and
the guidance relied upon. For example, if the corporation
applied provisions of the proposed regulations for certain line
items, it must list the sections of the proposed regulations
which it applied. If one or more line items are not based on
the proposed regulations, the corporation must provide an
explanation of the legal basis for the line items; for example,
the statute or applicable notice provision.

Definitions
Applicable Corporation

An applicable corporation is, with respect to any tax year, any
corporation (other than an S corporation, a RIC, or a REIT)
that satisfies an average annual adjusted financial statement
Instructions for Form 4626 (2024)

income test (the AFSI Test) for 1 or more tax years which are
prior to the tax year and end after December 31, 2021. See
section 59(k)(1)(A). Also, see the instructions for Part
I—Applicable Corporation Determination.

Adjusted Financial Statement Income (AFSI)

AFSI is, with respect to any corporation for any tax year, the
corporation’s net income or loss on its applicable financial
statement (AFS) (defined later) for that tax year with specific
adjustments including those noted below. See sections 56A
and 59(k) for more information. Also, see the instructions for
Part I—Applicable Corporation Determination, and Part
II—Corporate Alternative Minimum Tax (CAMT).
• Section 56A(c)(1) provides that appropriate adjustments to
AFSI shall be made in any case in which an AFS covers a
period other than the tax year.
• If the corporation is part of a tax consolidated group for any
tax year, the AFSI for that group for that tax year must take
into account items on the group’s AFS that are properly
allocable to the group’s members.
• For any corporation that is not included on a consolidated
return with the taxpayer corporation, the taxpayer
corporation's AFSI with respect to the other corporation is
determined by only taking into account the dividends
received from that corporation and other amounts which are
includible in gross income or deductible as a loss under
Chapter 1 of the Internal Revenue Code (other than amounts
required to be included under sections 951 and 951A) with
respect to that corporation.
• The term “CAMT entity” means any entity identified in
section 7701 and the related regulations, other than a
disregarded entity. See Proposed Regulations section
1.56A-1(b)(8).
• If a CAMT entity is a partner in a partnership, the CAMT
entity’s AFSI with respect to that partnership is adjusted to
consider only the CAMT entity’s distributive share of that
partnership’s AFSI. A partnership’s AFSI is the net income or
loss on that partnership’s AFS adjusted under rules similar to
those in section 56A.
• A disregarded entity or branch and the CAMT entity that
owns the disregarded entity or branch (including through
other disregarded entities or branches) are treated as a
single CAMT entity for purposes of determining AFSI. See
Proposed Regulations section 1.56A-9.
• If the CAMT entity is a U.S. shareholder of one or more
controlled foreign corporations (CFCs), its AFSI with respect
to the CFCs is adjusted to take into account its pro-rata share
(determined under rules similar to the rules in section 951(a)
(2)) of items taken into account in calculating the net income
or loss set forth on each CFC's AFS, as adjusted under rules
similar to those that apply in determining AFSI. This amount
is referred to as a CFC’s adjusted net income or loss.
Proposed Regulations section 1.56A-6(c) provides that a
CFC’s adjusted net income or loss is not limited to effectively
connected income. If the AFSI adjustment is negative, no
adjustment is made for that tax year. However, any
adjustment in a succeeding tax year is reduced by that
negative amount.
A foreign corporation's AFSI is generally determined under
the principles of section 882, which provides that a foreign
corporation is subject to CAMT only on income that is
effectively connected with the conduct of a trade or business
in the United States.
Note. Proposed Regulations section 1.56A-7 provides that a
foreign corporation’s AFSI is adjusted to take into account
Instructions for Form 4626 (2024)

only amounts and items that would be included in income
effectively connected with the conduct of a trade or business
within the United States or allowable as a deduction by such
corporation for purposes of section 882(c) had such amount
or item accrued for regular tax purposes in the tax year.
• AFSI is adjusted to disregard federal income taxes, and
income, war profits, and excess profits taxes (within the
meaning of section 901), with respect to a foreign country or
U.S. territory which are taken into account on the
corporation's AFS.
• A section 1381 cooperative’s AFSI excludes section
1382(b) cooperative patronage dividends and per-unit retain
allocations not otherwise used in calculating AFSI.
• An Alaska native corporation’s AFSI is adjusted to allow:
1. Cost recovery and depletion attributable to property
with a basis determined by the Alaska Native Claims
Settlement Act (the Act) (43 U.S.C. section 1602(c)); and
2. Deductions for amounts payable under section 7(i) or
7(j) of the Act (43 U.S.C. section 1602(i) and (j)) only when
the deductions are allowed for federal income tax purposes.
(“Federal income tax purposes” as used in these instructions
excludes CAMT.)
• AFSI excludes amounts treated as payments against a
federal income tax pursuant to an election under section
48D(d) or section 6417 or, in the case of a CAMT entity that
relies on Proposed Regulations section 1.56A-12(b)(2),
certain amounts received from the transfer of an eligible
credit, as defined in section 6418(f)(1)(A).
• AFSI is adjusted to not include any item of income in
connection with a mortgage servicing contract prior to the
amount being included in income for federal income tax
purposes.
• AFSI adjustments for covered benefit plans are:
1. Adjustments to disregard any income, cost, or
expense that would otherwise be included on the AFS in
connection with any covered benefit plan;
2. Increases for any covered benefit plan income that is
included in the CAMT entity’s gross income for federal
income tax purposes; and
3. Decreases for any covered benefit plan deduction
allowed to the CAMT entity for federal income tax purposes.
A covered benefit plan under section 56A(c)(11)(B) is a
defined benefit plan (other than a multiemployer plan
described in section 414(f)) that is qualified under section
401(a) with a trust exempt under section 501(a), any qualified
foreign plan as defined in section 404A(e), or any other
defined benefit plan which provides post-employment
benefits other than pension benefits.
• The AFSI of a tax-exempt entity subject to the section 511
unrelated business income tax is adjusted to only take into
account AFSI (if any) of an unrelated trade or business (as
defined in section 513) of the organization, subject to the
modifications to unrelated business taxable income
described in section 512(b). AFSI determined under the
preceding sentence includes any unrelated debt-financed
income determined under section 514. See section 512(b)
(4).
• AFSI is reduced by section 167 depreciation deductions
on section 168 property that are allowed in calculating
taxable income for the tax year and adjusted to remove any
book expense, depreciation expense, or other cost recovery
expense included in the CAMT entity’s AFS for the section
168 property.

3

• AFSI is reduced by any qualified wireless spectrum
amortization deductions allowed under section 197 in
calculating taxable income for the tax year and adjusted to
remove any book expense, amortization expense, or other
cost recovery expense included in the CAMT entity’s AFS for
the qualified wireless spectrum. For AFSI purposes, qualified
wireless spectrum is wireless spectrum that is used in the
trade or business of a wireless telecommunications carrier
and was acquired after December 31, 2007, and before
August 16, 2022.
• Proposed Regulation section 1.56A-27(b) provides that
AFSI of a foreign government is adjusted so as not to take
into account any amount of FSI that, if it were properly treated
as gross income for regular tax purposes, would be excluded
from gross income and exempt from taxation under subtitle A
pursuant to section 892.
• Section 56A(c)(15) authorizes guidance providing for
additional adjustments to AFSI, including those necessary to
prevent the duplication or omission of an item. Proposed
Regulations section 1.56A-17 provides for additional
adjustments to AFSI available to corporations who rely on the
interim guidance. See Interim Guidance, earlier.
Applicable Financial Statement (AFS)

Proposed Regulations section 1.56A-2 defines a
corporation’s “AFS” as the corporation’s highest priority
financial statement of the following financial statements
which are listed in descending order of priority: either a
certified generally accepted accounting principles (GAAP)
statement, an international financial reporting standards
(IFRS) statement, a financial statement prepared in
accordance with other generally accepted accounting
standards or an “other statement” filed with a Federal, State,
or foreign government agency thereof or a self-regulatory
organization, as provided in Proposed Regulations section
1.56A-2(c)(1) through (4). For a corporation that is relying on
the proposed regulations, and does not have a statement
described in the preceding sentence, the AFS is an
“unaudited external statement,” or a federal income tax return
or information return filed with the IRS, as provided in
Proposed Regulations sections 1.56A-2(c)(5) and (6). These
statements are described in more detail below in their
descending order of priority.
• A GAAP statement is an audited financial statement, other
than a tax return, that is certified as being prepared in
accordance with U.S. generally accepted accounting
principles and is:
1. A Form 10-K (or successor form), or annual statement
to shareholders, filed with the U.S. Securities and Exchange
Commission (SEC);
2. A financial statement that is used for credit purposes;
reporting to shareholders, partners, or other proprietors, or to
beneficiaries; or any other substantial nontax purpose; or
3. A financial statement filed with the federal government
or any federal agency, other than the SEC or the IRS.

• An IFRS statement is an audited financial statement, other
than a tax return, that is certified as being prepared in
accordance with international financial reporting standards
and is:
1. Filed with the SEC or an agency of a foreign
government that is equivalent to the SEC;
2. A financial statement that is used for credit purposes;
reporting to shareholders, partners, or other proprietors, or to
beneficiaries; or any other substantial nontax purpose; or
4

• A financial statement filed with the federal government, any
federal agency, a foreign government, or agency of a foreign
government, other than the SEC, the IRS, or an agency that
is equivalent to the SEC or the IRS.
• A financial statement prepared in accordance with
accepted accounting standards other than GAAP and IFRS
that are issued by an accounting standards board charged
with developing accounting standards for one or more
jurisdictions and is:
1. Filed with the SEC or an agency of a foreign
government that is equivalent to the SEC;
2. A financial statement that is used for credit purposes;
reporting to shareholders, partners, or other proprietors, or to
beneficiaries; or any other substantial nontax purpose; or
3. A financial statement filed with the federal government,
any federal agency, a foreign government, or agency of a
foreign government, other than the SEC, the IRS, or an
agency that is equivalent to the SEC or the IRS.
An “other statement” is a financial statement, other than a
tax return or a financial statement described above, filed with
the federal government or any federal agency, a state
government or state agency, a foreign government or foreign
agency, or a self-regulatory organization including, for
example, a financial statement filed with a state agency that
regulates insurance companies or the Financial Industry
Regulatory Authority, or a comparable foreign self-regulatory
organization.
If none of the above financial statements exist, the AFS
can be an unaudited external statement. An unaudited
external statement is a financial statement, other than a tax
return or a financial statement described above, that is
unaudited (or audited but not certified within the meaning of
Proposed Regulation section 1.56A-2(d)), prepared for an
external non-tax purpose, using (i) GAAP; (ii) IFRS; or (iii) any
other accepted accounting standards that are issued by an
accounting standards board charged with developing
accounting standards for one or more jurisdictions. If an
unaudited external statement also does not exist, the AFS for
a CAMT entity that is not a controlled foreign corporation
(CFC) can be a federal income tax return or information
return filed with the IRS, or, for a CAMT entity that is a CFC,
Form 5471, Information Return of U.S. Persons With Respect
to Certain Foreign Corporations (or any successor form).
Consolidated AFS and separate AFS. If a CAMT entity’s
financial results are reported on an AFS other than a tax
return with one or more other CAMT entities (consolidated
AFS), the consolidated AFS with the highest priority under
Proposed Regulations sections 1.56A-2(c)(1) through (5) is
generally the AFS of the CAMT entity. However, if a CAMT
entity’s financial results are reported on a consolidated AFS
and separately reported on an AFS that is of equal or higher
priority to the consolidated AFS (separate AFS), the CAMT
entity’s AFS is the separate AFS except as provided below.
See Proposed Regulations section 1.56A-2(g)(1).
A member of a tax consolidated group must prioritize a
consolidated AFS that includes other members of its tax
consolidated group over a separate AFS pursuant to special
rules. See Proposed Regulations sections 1.56A-1(c)(2)(i)
and 1.56A-2(g)(2)(i) through (iv) for additional details
regarding this exception.
If a CAMT entity is a member of a foreign-parented
multinational group (FPMG) whose common parent prepares
a consolidated AFS (FPMG consolidated AFS) that includes
the CAMT entity, the corporation must use the FPMG
Instructions for Form 4626 (2024)

consolidated AFS regardless of whether the corporation's
financial results also are reported on a separate AFS.
See Proposed Regulations section 1.56A-2(g)(2)(v).
Foreign-parented multinational group (FPMG). To
determine the FPMG and its members, see section 59(k).
Also, see Proposed Regulations section 1.59-3.
FPMG means, for any tax year, two or more entities, if:
1. At least one entity is a domestic corporation and
another is a foreign corporation,
2. Those entities are included in the same applicable
financial statement for that year, and
3. Either the common parent of those entities is a foreign
corporation or the entities are treated as having a common
parent that is a foreign corporation.
For this purpose, if a foreign corporation is engaged in a
trade or business within the United States, that trade or
business is treated as a separate domestic corporation that is
wholly owned by the foreign corporation.

Special Rules
AFSI Test
General AFSI Test
For purposes of determining whether a corporation satisfies
the general AFSI test for a tax year prior to the current tax
year, the following apply. See section 59(k)(1). Also, see
Proposed Regulations section 1.59-2(c)(1).
• A corporation meets the general AFSI test for that tax year
when the corporation’s average annual AFSI for the
3-tax-year period ending with the tax year exceeds $1 billion.
• Solely for purposes of determining whether a corporation
is an applicable corporation, all AFSI of members of a
controlled group treated as a single employer with the
corporation under section 52(a) or (b) (“controlled group”) is
included in the corporation’s AFSI.
• For purposes of determining the AFSI of the corporation
and all members of the controlled group under the general
AFSI test, the AFSI adjustments for financial statement net
operating losses under section 56A(d), partnership
distributive share under section 56A(c)(2)(D)(i), and covered
benefit plans under section 56A(c)(11) do not apply.

AFSI Test Applicable to Foreign-Parented
Multinational Group (FPMG) (FPMG AFSI Test)
If a corporation is an FPMG member for any tax year, it meets
the FPMG AFSI test if the FPMG $1 billion AFSI test and the
FPMG $100 million AFSI test described below are satisfied.
See section 59(k)(1). Also, see Proposed Regulations
section 1.59-2(c)(2)(i).
FPMG $1 billion AFSI test. A corporation meets the FPMG
$1 billion AFSI test for the tax year prior to the current tax
year if the corporation’s average annual AFSI for the
3-tax-year period ending with the tax year exceeds $1 billion.
For purposes of this determination, the AFSI of the
corporation includes the AFSI of all other members of the
FPMG and the AFSI of all members of the controlled group
other than persons that are members of the FPMG. See
section 59(k). Also, see Proposed Regulations section
1.59-2(c)(2)(ii).

Instructions for Form 4626 (2024)

For purposes of calculating the AFSI of a corporation that
is an FPMG member (including the AFSI of other members of
the FPMG and the controlled group for aggregation
purposes) under the FPMG $1 billion AFSI test, the AFSI
adjustments for financial statement net operating losses
under section 56A(d), partnership distributive share under
section 56A(c)(2)(D)(i), pro rata CFC adjusted net income or
loss under section 56A(c)(3), effectively connected income of
foreign corporations under 56A(c)(4), and covered benefits
plans under 56A(c)(11) do not apply.
FPMG $100 million test. A corporation meets the FPMG
$100 million test for the tax year prior to the current tax year if
the corporation's average annual AFSI for the 3-tax-year
period ending with the tax year is $100 million or more. For
purposes of this determination, the AFSI of the corporation
includes the AFSI of all members of the controlled group. See
section 59(k)(1). Also, see Proposed Regulations section
1.59-2(c)(2)(iii).
For purposes of calculating the AFSI of a corporation that
is an FPMG member (including the AFSI of other members of
the controlled group for aggregation purposes) under the
FPMG $100 million test, the AFSI adjustments for financial
statement net operating losses under section 56A(d),
partnership distributive share under 56A(c)(2)(D)(i), and
covered benefit plans under section 56A(c)(11) do not apply.

Additional Rules Applicable to the General AFSI
Test and the FPMG AFSI Test
If a corporation has been in existence for less than 3 tax
years of the 3-tax-year period, the AFSI test is applied by
averaging the tax years of the 3-tax-year period during which
the corporation existed. AFSI for any tax year of fewer than
12 months shall be annualized by multiplying the AFSI for the
short period by 12 and dividing the result by the number of
months in the short period. See section 59(k)(1)(E). Also, see
Proposed Regulations section 1.59-2(d).

Simplified Method for Determining Applicable
Corporation Status
Proposed Regulations section 1.59-2(g)(2) provides that a
corporation may choose to apply the safe harbor method
(simplified method) in lieu of the AFSI Test for purposes of
determining whether it is an applicable corporation. Under
the simplified method, a corporation determines whether it is
an applicable corporation by applying the AFSI test with the
following modifications.
• The general AFSI test and the FPMG $1 billion AFSI test
are applied by substituting “$500 million” for “$1 billion.”
• The FPMG, $100 million AFSI test is applied by
substituting “$50 million” for “$100 million.”
• AFSI is determined by considering only the following
adjustments.
1. If the financial results of a CAMT entity are reported on
the same consolidated financial statement for a group of
CAMT entities (AFS Group), the members of the group that
are part of a test group are treated as a single CAMT entity.
2. Disregard federal income taxes, or income, war profits,
and excess profits taxes (within the meaning of section 901),
with respect to a foreign country or U.S. territory which are
taken into account on the corporation's AFS. See Proposed
Regulations section 1.59-2(g)(2)(iii)(B).

5

3. For an organization subject to tax under section 511,
AFSI only takes into account the AFSI (if any) of an unrelated
trade or business (as defined in section 513) of such
organization, subject to the modifications to unrelated
business taxable income described in section 512(b). This
adjustment includes any unrelated debt-financed income
determined under section 514. See Proposed Regulations
section 1.59-2(g)(2)(iii)(B).
• In applying the FPMG $100 million test, a foreign
corporation's AFSI is calculated by considering only the
income items that are effectively connected with the conduct
of a U.S. trade or business. See Proposed Regulations
section 1.59-2(g)(2)(iii)(B).
• If a corporation has an AFS covering a period (AFS year)
different from its tax year, the general AFSI test and the
FPMG AFSI test are applied using the 3-AFS-year period
ending during such tax year rather than the 3-tax-year period
ending with such tax year. See Proposed Regulations section
1.59-2(g)(2)(iv)(A).
The rules for new corporations and short years are applied
using AFS years rather than tax years. See Proposed
Regulations section 1.59-2(g)(2)(iv)(B).

Calculating CAMT

For the tax year of an applicable corporation, a CAMT liability
arises to the extent the tentative minimum tax for the year
exceeds the sum of the regular income tax imposed for the
tax year plus the base erosion minimum tax (imposed under
section 59A). The tentative minimum tax is the excess of 15%
of AFSI over the corporate alternative minimum tax foreign
tax credit (CAMT FTC). For any corporation that is not an
applicable corporation, the tentative minimum tax for the tax
year is zero.
Reduction for financial statement net operating loss
(FSNOL). In calculating CAMT, AFSI is reduced by the
lesser of:
1. The aggregate amount of FSNOL carryovers to the tax
year, or
2. 80% of AFSI computed without regard to the FSNOL
reduction allowed.
An FSNOL for any tax year is the amount of the net loss (if
any) on the corporation's AFS determined with regard to
AFSI general adjustments under section 56A(c), but without
regard to an FSNOL reduction under section 56A(d), for tax
years ending after 2019. An FSNOL for any tax year is an
FSNOL carryover to the tax year following the tax year of the
loss. The portion of such loss that is carried to subsequent
years is determined by subtracting from the loss, for each
preceding tax year, the lesser of the amount of the loss or
80% of AFSI for the tax year (determined without regard to
the FSNOL adjustment), regardless of whether the
corporation was an applicable corporation in any tax year.
See Proposed Regulations section 1.56A-23 for more details.
For purposes of determining the average annual
AFSI of the corporation and all members of the test
CAUTION group under the General AFSI Test, the reduction for
financial statement net operating losses does not apply.

!

Corporate alternative minimum tax foreign tax credit
(CAMT FTC). If an applicable corporation elects to take a
section 901 foreign tax credit for regular tax for a tax year, the
CAMT FTC is an amount equal to the sum of:
1. The lesser of:
6

a. The aggregate of the applicable corporation's pro-rata
share (as determined under section 56A(c)(3)) of income,
war profits, and excess profits taxes (within the meaning of
section 901) imposed by any foreign country or U.S. territory
that are taken into account on the AFS of each CFC with
respect to which the applicable corporation is a U.S.
shareholder and are paid or accrued (for federal income tax
purposes) by each CFC, or
b. The applicable corporation's pro-rata share
(determined under rules similar to the rules under section
951(a)(2)) of the adjusted net income or loss of CFCs,
multiplied by 15%; plus
2. For an applicable corporation that is a domestic
corporation, the income, war profits, and excess profits taxes
(within the meaning of section 901) imposed by any foreign
country or U.S. territory to the extent that such taxes are
taken into account on the applicable corporation’s AFS and
are paid or accrued (for federal income tax purposes) by the
applicable corporation.
Proposed Regulation section 1.56A-8(d)(1) describes
when a foreign tax is treated as taken into account. Proposed
Regulation section 1.59-4(d) provides rules for determining
an applicable corporation’s pro-rata share of CFC taxes.
Proposed Regulation section 1.59-4(g) describes the
treatment of partnership taxes.

Credit for Prior Year Minimum Tax

A corporation may take a credit against the regular tax and
the base erosion minimum tax for alternative minimum tax
incurred in prior years. See Form 8827, Credit for Prior Year
Minimum Tax—Corporations, for details.

Specific Instructions
Item A

If the corporation is a member of a controlled group, check
the "Yes" box in Item A. Also, complete Part V. See the
instructions for Part V.

Item B

If the corporation is a member of an FPMG, check the "Yes"
box. Also, complete Part V. See the instructions for Part V. In
addition, attach a statement described under Proposed
Regulations section 1.59-3(g)(4) disclosing the applicable
financial accounting standard used to determine if a
corporation is a member of an FPMG. See Proposed
Regulations section 1.59-3(g) for determining the applicable
financial accounting standard.

Part I—Applicable Corporation
Determination

If the corporation has already determined it is an applicable
corporation for purposes of the CAMT, skip Part I. Otherwise
complete Part I to determine if the corporation is an
applicable corporation. An applicable corporation is any
corporation that satisfies the AFSI Test for 1 or more tax
years prior to the current tax year and end after December
31, 2021. If the corporation is an FPMG member for any tax
year, the FPMG AFSI Test applies. See section 59(k) and
AFSI Test, earlier.
A corporation may choose to apply the safe harbor
method (simplified method) in lieu of the AFSI Test for
purposes of determining whether it is an applicable
Instructions for Form 4626 (2024)

corporation. See the Instructions for Form 1120, Schedule K,
question 29c, or the applicable question on the corporation's
return.
If a corporation has been in existence for fewer than 3 tax
years of the 3-tax-year period, the AFSI test is applied to that
corporation by averaging the tax years of the 3-tax-year
period during which that corporation existed. For example, a
corporation with a calendar tax year is formed on January 1,
2022. Only the calendar tax years ended December 31,
2022, and December 31, 2023, are included in the AFSI test
in determining whether the corporation is an applicable
corporation for the tax year ended December 31, 2024.
For a corporation with AFSI for any tax year of less than 12
months included in the 3-tax-year period, the AFSI of that
corporation is annualized by multiplying the AFSI for the short
period by 12 and dividing the result by the number of months
in the short period. For example, a corporation with a
calendar tax year is formed on July 1, 2021. The AFSI for the
tax year ended December 31, 2021, is multiplied by 12 and
then divided by 6 when computing the 3-year annual average
AFSI on the applicable line. The resulting 3-year annual
average AFSI with the AFSI for tax years ended December
31, 2022, and December 31, 2023, is used to determine
whether the corporation is an applicable corporation for the
tax year ended December 31, 2024.
AFSI for the short period to be annualized does not
include those items described as extraordinary items in
Regulations section 1.6655-2(f)(3)(ii)(A) to the extent that the
items are not otherwise disregarded in determining AFSI,
either because of an AFSI adjustment or because the items
are not included in FSI. However, the items are included in
AFSI for the annualized 12-month period after the AFSI for
the short period is annualized. See Proposed Regulations
section 1.59-2(d)(2)(ii).
Note. If it has been determined in either the current or prior
tax years that the corporation is an applicable corporation,
skip Part I and continue to Part II.
Columns a, b, and c. In columns (a), (b), and (c), enter the
required information for the 3-tax-year period ending prior to
the current tax year. For example, when a corporation with a
calendar tax year determines whether it is an applicable
corporation for the tax year ending December 31, 2024, the
3-tax-year period includes the tax years ended December 31,
2023, December 31, 2022, and December 31, 2021.
Line 1a. Enter the net income or loss from the corporation’s
AFS. If the corporation’s AFS is a consolidated AFS, enter
the consolidated net income or loss which includes net
income or loss attributable to noncontrolling interests. If the
corporation has been in existence for less than 3 tax years of
the 3-tax-year period, enter information for the period during
which the corporation existed.
Line 1b. Enter the net income or loss of the other entities the
AFSI of which is required to be aggregated with the AFSI of
the corporation for purposes of determining if the corporation
is an applicable corporation but that are not included in the
corporation's AFS. Include net income or loss of members of
the controlled group and corporate-owned disregarded
entities that were not included in the corporation's AFS, and if
the corporation is an FPMG member, also include the net
income or loss of FPMG members that were not included
already. If the other entity has been in existence for less than
3 tax years, enter information for the period during which the
corporation existed.
Instructions for Form 4626 (2024)

Line 1c. Enter net income or loss from entities included in
the AFS but that are not in the controlled group, or in the case
of an FPMG member, not in the FPMG or controlled group.
Add net loss and subtract net income.
Line 1d. Enter any consolidation entry adjustments made
attributable to entities the net income of which is included on
line 1a (but only to the extent such adjustments were not
reflected on line 1c). See Proposed Regulations sections
1.56A-1(c)(2) and (3) and 1.1502-56A(a)(2) and (c) for
details.
Line 1e. Reserved for future use.
Lines 2a through 2z. Compute the adjustments for each of
the entities in the aggregation group and report the total
amount for all entities on the form.
Line 2a. Appropriate adjustments to AFSI are made when
the AFS reporting year covers a period other than the
corporation’s tax year.
Line 2b. In the case of any corporation which is not included
on a consolidated return with the taxpayer corporation, enter
the adjustment required by section 56A(c)(2)(C) with respect
to each entity in the aggregation group.
Line 2c. Aggregate pro-rata share of adjusted net income or
loss of CFCs.
Corporation that is not a member of an FPMG. For a
corporation that is not a member of an FPMG, if the
corporation is a U.S. shareholder of one or more CFCs, enter
the corporation's aggregate pro-rata share (determined under
rules similar to the rules under section 951(a)(2)) of the
adjusted net income or loss of its CFCs for the first, second,
and third preceding years from Form 4626, Schedule A,
column (i), line 31. See section 56A(c)(3)(A). If the aggregate
pro-rata share of the adjusted net income or loss of the
corporation’s CFCs is negative, enter zero.
Attach Schedule A (Form 4626), Pro-Rata Share of
Adjusted Net Income or Loss of CFCs Described in Section
56A(c)(3). Attach a separate Schedule A for each of column
(a), (b), and (c).
Corporation that is a member of an FPMG. If the
corporation is a member of an FPMG, enter zero.
Line 2d. Amounts that are not effectively connected to a
U.S. trade or business.
Corporation that is not a member of an FPMG. Enter
AFSI amounts from all foreign corporations that are in the
controlled group where such AFSI amounts are not effectively
connected with the conduct of a U.S. trade or business.
Corporation that is a member of an FPMG. If the
corporation is a member of an FPMG, enter zero.
Line 2e. Certain taxes. Enter an adjustment to AFSI to
disregard the amount of federal income taxes, and income,
war profits, and excess profits taxes (within the meaning of
section 901), with respect to any foreign country or U.S.
territory which are taken into account on the corporation’s
AFS.
Line 2f. For section 1381 cooperatives, enter an adjustment
to reduce AFSI by the amounts referred to in section 1382(b)
relating to patronage dividends and per-unit retain allocations
to the extent such amounts were not otherwise taken into
account in determining AFSI.
Line 2g. Alaska native corporations. Enter an adjustment
to allow cost recovery and depletion attributable to property
with a basis determined by the Alaska Native Claims
7

Settlement Act (the Act) and deductions for amounts payable
under section 7(i) or 7(j) of the Act which are allowed for
federal income tax purposes.
Line 2h. Certain credits. Enter an adjustment to disregard
any amounts treated as federal income tax credits under
section 48D(d) or section 6417 or certain amounts received
from the transfer of an eligible credit, as defined in section
6418(f)(1)(A), to the extent that these amounts were not
otherwise taken into account on line 2e.
Line 2i. Mortgage servicing income. Enter any
adjustments to defer items of income in connection with
mortgage servicing contracts so that they are not included in
AFSI prior to being included in income for federal income tax
purposes.
Line 2j. Tax-exempt entities. Enter adjustments to AFSI so
that only items from the corporation’s unrelated trade or
business activities (as defined in section 513), subject to the
modifications to unrelated business taxable income
described in section 512(b), are included in AFSI. The
adjustments to AFSI include any unrelated debt-financed
income determined under section 514.
Line 2k. Depreciation. Enter an adjustment which is the
difference between the section 167 depreciation deductions
on section 168 property allowed in calculating taxable
income for the tax year and the book expense, depreciation
expense, or other cost recovery expense included in the
CAMT entity’s AFS for such property. The adjustment is
negative if the section 167 depreciation deductions on
section 168 property exceed the book expense, depreciation
expense, or other cost recovery expense included in the
CAMT entity's AFS for such property. The adjustment is
positive if the book expense, depreciation expense, or other
cost recovery expense included in the CAMT entity's AFS for
section 168 property exceeds the section 167 depreciation
deductions on such property. Also enter any additional
adjustments, including those to account for the disposition of
property. See Interim Guidance, earlier.
Line 2l. Qualified wireless spectrum. Enter an adjustment
which is the difference between the qualified wireless
spectrum section 197 amortization allowed in calculating
taxable income for the tax year and the book expense,
amortization expense, or other cost recovery expense
included in the CAMT entity's AFS for such property. The
adjustment is negative if the section 197 amortization
deductions on qualified wireless spectrum exceed the related
book expense, amortization expense, or other cost recovery
expense included in the CAMT entity's AFS for such property.
The adjustment is positive if the book expense, amortization
expense, or other cost recovery expense included in the
CAMT entity's AFS for qualified wireless spectrum property
exceeds the section 197 amortization deductions on such
property. Also enter any additional adjustments, including
those to account for the disposition of property. See Interim
Guidance, earlier.
Line 2m. Covered transactions. If the corporation is
relying on interim guidance regarding covered transactions,
enter any AFSI adjustments that result from the application of
such guidance.
Line 2n. Adjustments related to bankruptcy and insolvency. If the corporation is relying on interim guidance
regarding bankrupt or insolvent corporations, enter any AFSI
adjustments that result from the application of such guidance.
8

Line 2o. Certain insurance company adjustments. If the
corporation is relying on interim guidance regarding certain
insurance company adjustments and other industry specific
adjustments, enter any AFSI adjustments that result from the
application of such guidance.
Lines 2p through 2s. Reserved for future use.
Line 2z. Other. Enter any other AFSI adjustments, including
adjustments to prevent omissions or duplications of any
items, as permitted by interim guidance. Use line 2z to enter
adjustments related to income of foreign governments.
Attach a statement describing the adjustment and amount. If
the corporation is relying on interim guidance regarding
certain hedging transactions, enter any AFSI adjustments
that result from the application of such guidance.
Line 3. Reserved for future use.
Line 7. 3-year average annual AFSI. Calculate the 3-year
average annual AFSI by dividing the amount on line 6 by the
number of tax years included on line 6. The average is
calculated using the period during which the corporation
existed. However, if the amount on line 6 includes AFSI for
any tax year of less than 12 months, annualize the amount for
each short period by multiplying the short-period AFSI shown
on line 5 by 12 and dividing the result by the number of
months in the short period. Then add the other amounts on
line 5 to the annualized amount and divide that total by the
number of tax years of the 3-tax-year period during which the
corporation existed.
Line 8. If line 7 exceeds $1 billion, check the “Yes” box on
line 8, and continue to line 9. If line 7 is $1 billion or less,
check “No.” Stop here. Attach the completed Form 4626 to
the corporation's income tax return for the current tax year.
Line 9. If the corporation is a member of an FPMG, check
“Yes,” and continue to line 10. If the corporation is not an
FPMG member, check “No,” and continue to Part II.
Line 10a. Enter the amount of AFSI from line 5.
Line 10b. Enter the AFSI amount of FPMG members that
are not members of the corporation's controlled group.
Line 10c. Subtract line 10b from line 10a. Enter that amount
on line 10c.
Line 11a. Enter the AFSI amount of members of the
controlled group that is not effectively connected with the
conduct of a U.S. trade or business. Enter AFSI income as a
negative number and AFSI losses as a positive number.
Line 11b. If the corporation is a U.S. shareholder of one or
more CFCs, enter the U.S. shareholder corporation's pro-rata
share (determined under rules similar to the rules under
section 951(a)(2)) of the adjusted net income or loss of its
CFCs for the first, second, and third preceding years from
Form 4626 Schedule A, column (i), line 31. If the pro-rata
share of adjusted net income or loss of the CFCs is negative,
enter zero. See Schedule A.
Attach Schedule A (Form 4626), Pro-Rata Share of
Adjusted Net Income or Loss of CFCs Described in Section
56A(c)(3). Attach a separate Schedule A for each of column
(a), (b), and (c).
Lines 11c and 11d. Reserved for future use.
Line 13. Combine lines 10c and 12. Enter the total on
line 13.

Instructions for Form 4626 (2024)

Line 15. 3-year average annual AFSI for purposes of the
$100 million test. Calculate the 3-year average annual
AFSI by dividing the amount on line 14 by the number of tax
years of the 3-tax-year period during which the corporation
existed. However, if the amount on line 14 includes AFSI for
any tax year of less than 12 months, annualize the amount for
each short period by multiplying the short-period AFSI shown
on line 13 by 12 and dividing the result by the number of
months in the short period. Then add the other amounts on
line 13 to the annualized amount and divide that total by the
number of tax years of the 3-tax-year period during which the
corporation existed.
Line 16. If Part I, line 15 is $100 million or more, check “Yes,”
and continue to Part II. If line 15 is less than $100 million,
check “No.” Attach the completed Form 4626 to the
corporation’s income tax return for the current tax year.
If the corporation does not meet the definition of
applicable corporation in Part I or has not been
CAUTION classified as an applicable corporation in a prior year,
do not complete Part II of Form 4626.

!

Part II—Corporate Alternative
Minimum Tax (CAMT)

CAMT applies if the tentative minimum tax for the tax year
exceeds the sum of the regular income tax plus the base
erosion minimum tax. The tentative minimum tax for the tax
year is the excess of 15% of AFSI for the tax year, over the
CAMT FTC for the tax year.
Line 1a. Net income or loss per AFS or consolidated net
income or loss per AFS (as appropriate). If the corporation’s
AFS is a consolidated AFS, enter consolidated net income or
loss set forth on the consolidated AFS for the current tax
year, which includes net income or loss attributable to
noncontrolling interests. Otherwise, enter the net income or
loss set forth on the corporation’s AFS for the current tax
year.
Line 1b. AFS net income or loss of other includible entities.
Enter the net income or loss of other includible entities not
included in the corporation’s AFS. For example, include net
income or loss reported on the corporation's AFS as
discontinued operations for any entity that is a member of the
affiliated group of corporations filing a consolidated tax
return. Add net income and subtract net loss.
Line 1c. Enter the net income or loss of excludible entities
(including corporations that are not part of the affiliated group
of corporations filing a consolidated tax return with the
applicable corporation) included in the corporation's AFS.
Add net loss and subtract net income.
Line 1d. Enter any consolidation entry adjustments made
attributable to entities the net income of which is included on
line 1a (but only to the extent such adjustments were not
reflected on line 1c). See Interim Guidance, earlier.
Line 1e. Reserved for future use.
Line 2a. Financial statements covering different tax
years. Appropriate adjustments to AFSI are made when the
AFS reporting year covers a period other than the
corporation's tax year.
Line 2b. Reserved for future use.
Line 2c. Corporations not included on the taxpayer’s
consolidated return. In the case of any corporation which
Instructions for Form 4626 (2024)

is not included on a consolidated return with the taxpayer
corporation, enter the adjustment required by section 56A(c)
(2)(C) with respect to such corporation. Also enter any
adjustments of a U.S. shareholder of a CFC resulting from
certain distributions received with respect to stock of the
CFC. See Interim Guidance, earlier.
Line 2d. Enter the adjustment(s) needed to include the
corporation’s distributive share of all partnership investment
AFSI.
Line 2e. If the corporation is a U.S. shareholder of one or
more CFCs, enter the corporation's aggregate pro-rata share
(determined under rules similar to the rules under section
951(a)(2)) of the adjusted net income or loss of its CFCs. If
the aggregate pro-rata share of the adjusted net income or
loss of its CFCs is negative, enter zero.
Note. Line 2e should equal Part IV, Section I, line 3f, and
Part VI, Section II, line 3.
Line 2f. In the case of an applicable corporation that is a
foreign corporation, enter any net income or loss included on
the corporation’s AFS that is not effectively connected with
the conduct of a U.S. trade or business. Add net loss and
subtract net income.
Line 2h. For section 1381 cooperatives, enter an adjustment
to reduce AFSI by the amounts referred to in section 1382(b)
(relating to patronage dividends and per-unit retain
allocations) to the extent such amounts were not otherwise
taken into account in determining AFSI.
Line 2i. Alaska native corporations. Enter an adjustment
to allow cost recovery and depletion attributable to property
with a basis determined by the Alaska Native Claims
Settlement Act (the Act) and deductions for amounts payable
under section 7(i) or 7(j) of the Act which are allowed for
federal income tax purposes.
Line 2j. Certain credits. Enter an adjustment to disregard
any amounts treated as federal income tax credits under
section 48D(d) or section 6417 or certain amounts received
from the transfer of an eligible credit, as defined in section
6418(f)(1)(A), to the extent that these amounts were not
otherwise taken into account on line 2g.
Line 2k. Mortgage servicing income. Enter any
adjustments to defer items of income in connection with
mortgage servicing contracts so that they are not included in
AFSI prior to being included in income for federal income tax
purposes.
Line 2l. Covered benefit plans. Enter adjustments needed
to adjust AFSI to disregard any income, cost, or expense that
would otherwise be included on the AFS in connection with
any covered benefit plan. Enter adjustments required to
increase AFSI by any covered benefit plan income and to
reduce AFSI by any covered benefit plan deductions, as
allowed under the applicable provision of the Internal
Revenue Code. See sections 56A(c)(11)(A)(i)–(iii).
Line 2m. Tax-exempt entities. Enter adjustments to AFSI
so that only items from the corporation’s unrelated trade or
business activities (as defined in section 513), subject to the
modifications to unrelated business taxable income
described in section 512(b) are included in AFSI. The
adjustments to AFSI include any unrelated debt-financed
income determined under section 514.
Line 2n. Depreciation. Enter an adjustment which is the
difference between the section 167 depreciation deductions
9

on section 168 property allowed in calculating taxable
income for the tax year and the book expense, depreciation
expense, or other cost recovery expense included in the
CAMT entity’s AFS for such property. The adjustment is
negative if the section 167 depreciation deductions on
section 168 property exceed the book expense, depreciation
expense, or other cost recovery expense included in the
CAMT entity's AFS for such property. The adjustment is
positive if the book expense, depreciation expense, or other
cost recovery expense included in the CAMT entity's AFS for
section 168 property exceeds the section 167 depreciation
deductions on such property. Also enter any additional
adjustments, including those to account for the disposition of
property. See Interim Guidance, earlier.
Line 2o. Qualified wireless spectrum. Enter an
adjustment which is the difference between the qualified
wireless spectrum section 197 amortization allowed in
calculating taxable income for the tax year and the book
expense, amortization expense, or other cost recovery
expense included in the CAMT entity’s AFS for such property.
The adjustment is negative if the section 197 amortization
deductions on qualified wireless spectrum exceeds the
related book expense, amortization expense, or other cost
recovery expense included in the CAMT entity's AFS for such
property. The adjustment is positive if the book expense,
amortization expense, or other cost recovery expense
included in the CAMT entity's AFS for qualified wireless
spectrum property exceeds the section 197 amortization
deductions on such property. Also enter any additional
adjustments, including those to account for the disposition of
property. See Interim Guidance, earlier.
Line 2p. Covered transactions. If the corporation is relying
on interim guidance, regarding covered transactions, enter
any AFSI adjustments that result from the application of such
guidance.
Line 2q. Adjustments related to bankruptcy and insolvency. If the corporation is relying on interim guidance
regarding bankrupt or insolvent corporations, enter any AFSI
adjustments that result from the application of such guidance.
Line 2r. Certain insurance company adjustments. If the
corporation is relying on interim guidance regarding certain
insurance company adjustments and other industry-specific
adjustments, enter any AFSI adjustments that result from the
application of such guidance.
Lines 2s through 2u. Reserved for future use.
Line 2z. Other. Enter any other AFSI adjustments, including
adjustments to prevent omissions or duplications of any
items, as permitted by Interim Guidance. Use line 2z to enter
adjustments related to income of foreign governments.
Attach a statement describing the adjustment and amount. If
the corporation is relying on interim guidance regarding
certain hedging transactions, enter any AFSI adjustments
that result from the application of such guidance.
Line 5. The amount of the FSNOL adjustment for the tax
year is limited to the lesser of:
1. The aggregate amount of FSNOL carryovers to the tax
year, or
2. 80% of AFSI computed without regard to the FSNOL
deduction allowed.
Maintain adequate records documenting both the amount
of FSNOL generated in the tax year and used in subsequent
tax years.
10

Line 10. Enter the corporation’s regular tax liability (as
defined in section 26(b)) minus any foreign tax credit, if any
(Form 1120, Schedule J, line 1a minus any foreign tax credit
entered on Schedule J, line 5a, or the applicable lines on the
corporation’s tax return).
Line 11. Base erosion minimum tax. Enter the base
erosion minimum tax amount, if any, from Form 1120,
Schedule J, line 1f, or the applicable line of the corporation's
tax return. See section 59A and Form 8991.

Part III—Adjustment for Certain Taxes
Under Section 56A(c)(5)
Federal income taxes, and income, war profits, and excess
profits taxes (within the meaning of section 901) with respect
to any foreign country or U.S. territory which are taken into
account on the corporation's AFS are disregarded for AFSI
purposes. Complete Part III to adjust for taxes described in
section 56A(c)(5).

Line 1. Enter any income, war profits, and excess profits
taxes (within the meaning of section 901) with respect to any
foreign country or U.S. territory which are taken into account
on the corporation's AFS in the current income tax provision.
Exclude any CFC income, war profits, and excess profits
taxes (within the meaning of section 901) with respect to a
foreign country or U.S. territory which are taken into account
on the CFC's AFS in the current income tax provision.
Line 2. Enter federal income taxes which are taken into
account on the corporation's AFS in the current income tax
provision.
Line 3. Enter any income, war profits, and excess profits
taxes (within the meaning of section 901) with respect to any
foreign country or U.S. territory which are taken into account
on the corporation's AFS in the deferred income tax
provision. Exclude any CFC income, war profits, and excess
profits taxes (within the meaning of section 901) with respect
to a foreign country or U.S. territory which are taken into
account on the CFC's AFS in the deferred income tax
provision.
Line 4. Federal deferred tax provision. Enter federal
income taxes which are taken into account on the
corporation's AFS in the deferred income tax provision.
Line 5. Enter the federal income taxes and income, war
profits, and excess profits taxes (within the meaning of
section 901) with respect to a foreign country or U.S. territory
taken into account on the corporation's AFS as part of equity
method investment income. Exclude any CFC income, war
profits, and excess profits taxes (within the meaning of
section 901) with respect to a foreign country or U.S. territory
which are taken into account on the CFC's AFS as part of
equity method investment income.
Lines 6a through 6h. Reserved for future use.
Line 6z. Income taxes in other places. Enter other federal
income taxes and income, war profits, and excess profits
taxes (within the meaning of section 901) with respect to a
foreign country or U.S. territory taken into account on the AFS
in determining net income in other places. Exclude any CFC
income, war profits, and excess profits taxes (within the
meaning of section 901) with respect to a foreign country or
U.S. territory which are taken into account on the CFC's AFS
in determining net income in other places.

Instructions for Form 4626 (2024)

Part IV—Corporate Alternative
Minimum Tax—Foreign Tax Credit

Complete Part IV if an applicable corporation elects to take
the section 901 foreign tax credit for regular tax. See section
59(l).
A foreign income tax is eligible to be claimed as a CAMT
FTC (eligible tax) in the tax year in which it is paid or accrued
for federal income tax purposes by either an applicable
corporation or a CFC with respect to which the applicable
corporation is a U.S. shareholder, provided the foreign
income tax has been taken into account on the AFS of such
applicable corporation or CFC.
Note. Report all items in Part IV in U.S. dollars.

Section I—CAMT Foreign Tax Credit

Use Section I to compute the total domestic corporation AMT
foreign income taxes.

Line 1a. Enter total foreign taxes paid or accrued as
reported on Form 1118, Schedule B, Part I, column 2(j).
Lines 1b through 1g. Enter the description and amounts for
adjustments to the line 1a amount listed above. On line 1b,
enter any other foreign income taxes not included on line 1a.
Enter any other adjustments to line 1a on lines 1c through 1g.
Line 3a. Pro-rata share of CFC CAMT foreign income
taxes. Enter the amount from Part IV, Section II, line 11,
column (n).
Line 3b. Enter adjustments to the line 3a amount listed
above.
Line 3c. Enter the section 59(l)(2) carryover of excess
foreign taxes from Part IV, Section III, line 4, column (vii).
Line 3e. Enter the 15% specified in section 55(b)(2)(A)(i).
Line 3f. Enter the amount from Part VI, Section II, line 3.
Note. The amount on line 3f should be the same as the
pro-rata share of adjusted net income or loss of a CFC from
Part II, line 2e, and Part VI, Section II, line 3.
Lines 4 and 5. Reserved for future use.

Section II—Allowable CFC CAMT Foreign
Income Taxes
Column (b). Enter the CFC’s employer identification number
(EIN) or other reference identification number.
Column (c). Enter the adjusted net income or loss of each
CFC as reported on each CFC’s Form 5471 Schedule H-1,
line 4 in U.S. dollars.
Column (d). Enter the income, war profits, and excess
profits taxes (within the meaning of section 901) imposed by
a foreign country or U.S. territory which are taken into
account on the CFC's AFS with respect to which the
applicable corporation is a U.S. shareholder and paid or
accrued (for federal income tax purposes) by the CFC. See
section 59(l)(1).
Columns (e) through (k). Adjustments to column (d). Enter
the description at the top of each adjustment column. Enter
the adjustment amount on each line for each CFC that may
have such adjustment with respect to the amount included in
column (d).

Column (n). Enter the corporation’s pro-rata share of the
CFC’s CAMT foreign income taxes.

Section III—CAMT Foreign Tax Credit Carryover
for CFCs
Line 1. Foreign tax carryover from the prior tax year. If
applicable, enter amounts from the appropriate columns of
line 8 of the prior year Form 4626, Part IV, Section III.
Note. For tax years beginning before 2023, the relevant
preceding tax year columns should be left blank.
Lines 2a through 2g. Adjustments to line 1. Enter the
description and amounts of adjustments to the line 1 amount
listed above.
Line 5. Complete line 5 only if the applicable corporation has
excess CFC CAMT foreign tax credit limitation. Excess CFC
CAMT foreign tax credit limitation exists when the applicable
corporation’s CFC CAMT foreign tax credit limitation (Part IV,
Section I, line 3f) exceeds its allowable controlled CFC CAMT
foreign income taxes (Part IV, Section I, line 3a).
Enter in each column the foreign tax carryover utilized in
the current tax year. Starting with column (i), the amount to
be entered on line 5 of a given column will be the amount on
line 4 of that column, but only to the extent that it does not
exceed:
• The amount of excess CFC CAMT foreign tax credit
limitation (defined above), less
• The sum of all amounts entered in all previous columns of
line 5.
The total on line 5, column (vii), cannot exceed the excess
CFC CAMT foreign tax credit limitation.
Line 6. Complete line 6 only regarding the fifth preceding tax
year (and the “Total” column). For the fifth preceding tax year
(column (i)), combine lines 4 and 5 and enter the result on
line 6, column (i).
Line 7. Enter the section 59(l)(2) foreign tax carryover
generated in the current tax year. The line 7, column (vi)
foreign tax carryover generated in the current tax year is the
difference between the allowable CFC CAMT foreign income
taxes (Part IV, Section I, line 3a) and the CFC CAMT foreign
tax credit limitation (Part IV, Section I, line 3g).

Part V—Members of a Controlled
Group Treated as a Single Employer
and FPMG Members Taken Into
Account in “Applicable Corporation”
Determination

If the corporation answers “Yes” to either Item A or Item B at
the top of page 1, then the corporation must complete Part V.
Enter the requested information for the entities included in
the taxpayer’s applicable corporation determination.

!

CAUTION

Incomplete or nonspecific responses, including
phrases such as “available upon request” are not
sufficient responses.

Column (a). Enter the name of the member of a controlled
group and/or FPMG member included in the corporation’s
applicable corporation determination.

Column (m). Reserved for future use.
Instructions for Form 4626 (2024)

11

Column (b). Enter the EIN of the member of a controlled
group and/or FPMG member included in the corporation’s
applicable corporation determination.
Column (c). Member of a controlled group. Check the box
on the appropriate line if the entity is a member of a
controlled group. See Proposed Regulations section
1.59-2(e)(1) for the definition of a controlled group.

Part VI, Section I. Attach a statement summarizing the
amount of CFC adjustment carryover generated in each prior
year, the amount of each such CFC adjustment carryover that
has been used in prior years, and the amount of such CFC
adjustment carryovers available to be used in the current
year, as illustrated below.
(A) CFC
Adjustment
Carryover
Generated

(B) Amount of
Carryover
From (A) Used
in Prior Years

(C) Amount of
Carryover From
(A) Available
for Use

20X1

100x

70x

30x

20X2

0

n/a

n/a

20X3

40x

0

40x

Column (d). FPMG members. Check the box on the
appropriate line if the entity is a member of an FPMG. See
section 59(k)(2) and the AFSI Test section, earlier.
Column (e). Enter the EIN or foreign taxpayer identification
number (FTIN) of the U.S. income tax return (if any) on which
the majority of the member’s income is reported for the tax
year. For this question only, majority means more than 50%
of the member’s financial statement income.
Column (f). Enter each included member's net income or
loss reported on its AFS for the current tax year.

Part VI—Aggregate Pro-Rata Share of
Adjusted Net Income or Loss of CFCs
Described in Section 56A(c)(3)
Section I—Pro-Rata Share of Adjusted Net
Income or Loss of CFCs Described in Section
56A(c)(3)
Column (a). Enter the name of the CFC.
Column (b). Enter the EIN or reference ID number of the
CFC.
Column (c). Enter the country code for the country in which
the CFC was incorporated. See IRS.gov/CountryCodes.
Column (d). Enter the pro-rata share of items taken into
account in computing the adjusted net income or loss of a
CFC as reported on each CFC’s Schedule H-1 (Form 5471)
in U.S. dollars. See section 56A(c)(3). In determining the
adjusted net income or loss of a CFC, disregard CFC federal
income taxes, and income, war profits, and excess profits
taxes (within the meaning of section 901) with respect to a
foreign country or U.S. territory taken into account in income
on the CFC’s AFS. See section 56A(c)(5).

Section II—Section 56A(c)(3)(B) Negative
Adjustment
Line 1. In general, enter the amount from Section I, line 42.
However, if the applicable corporation relies on the specified
proposed regulations and does not choose to have the
benefits of subpart A of part III of subchapter N of chapter 1
for the tax year, then reduce the amount on Section I, line 42
by the amount of the reduction described in Proposed
Regulations section 1.56A-6(b)(2) and enter the result here.
Line 2. Enter the aggregate amount of available CFC
adjustment carryovers as defined in Proposed Regulations
section 1.56A-6(b)(6). A CAMT entity that is a U.S.
shareholder of one or more CFCs makes a single adjustment
to the CAMT entity’s AFSI for its tax year that is equal to the
aggregate of the CAMT entity’s pro-rata share of the adjusted
net income or loss of each such CFC. If a prior tax year
aggregate adjustment is negative with respect to a tax year of
a U.S. shareholder, such loss is carried forward to the future
tax years and may reduce the current tax year aggregate
pro-rata share of CFC’s adjusted net income from the total of
12

Note. The amount entered on Line 2 should equal the sum
of the amounts reported in column (C) above.
Line 3. Combine lines 1 and 2. If more than zero, enter the
total on line 3 and on Part II, line 2e, and Part IV, Section I,
line 3f. If zero or less, enter zero (-0-) on line 3 and on Part II,
line 2e, and Part IV, Section I, line 3f, and go to line 4.
Line 4. Combine lines 1 and 2. If less than zero, enter the
combined total as a negative number. If zero or more, enter 0.

Schedule A—Pro-Rata Share of
Adjusted Net Income or Loss of CFCs
Described in Section 56A(c)(3)

Note. Complete a separate Schedule A for each of the 3
preceding tax years.
Column (a). Enter the name of the CFC.

Column (b). Enter the EIN or reference ID number of the
CFC.
Column (c). Enter the country code for the country in which
the CFC was incorporated. See IRS.gov/CountryCodes.
Column (d). Enter the CFC’s current year net income or
(loss) in U.S. dollars for the relevant tax year.
Column (e). Enter the section 56A(c)(3) adjustments in U.S.
dollars for the relevant tax year.
Column (f). Combine column (d) and column (e).
Columns (g) and (h). Reserved for future use.
Column (i). Enter the pro-rata share of the adjusted net
income or loss of the CFC described in section 56A(c)(3) in
U.S. dollars.
Reduce the amount reported on line 31 by the CFC
adjustment carryovers available for the relevant year, if any.
Enter the reduced amount in the appropriate column of Part I,
line 2c or, if a member of an FPMG, the appropriate column
of Part I, line 11b.
Note. When calculating the CFC adjustment carryovers
available for this purpose, the adjustment provided under
Proposed Regulations section 1.56A-6(b)(2) is not taken into
account. Attach a statement similar to the example shown for
Part VI, Section II, line 2 that summarizes the amount of CFC
adjustment carryover generated in each prior year, the
amount of each such CFC adjustment carryover that has
been used in prior years, and the amount of such CFC
Instructions for Form 4626 (2024)

adjustment carryovers available to be used in the current
year.

returns and return information are confidential, as required by
section 6103.

Paperwork Reduction Act Notice. We ask for the
information on this form to carry out the Internal Revenue
laws of the United States. You are required to give us the
information. We need it to ensure that you are complying with
these laws and to allow us to figure and collect the right
amount of tax.
You are not required to provide the information requested
on a form that is subject to the Paperwork Reduction Act
unless the form displays a valid OMB control number. Books
or records relating to a form or its instructions must be
retained as long as their contents may become material in the
administration of any Internal Revenue law. Generally, tax

The time needed to complete and file this form will vary
depending on individual circumstances. The estimated
burden for business taxpayers filing this form is approved
under OMB control number 1545-0123 and is included in the
estimates shown in the instructions for their business income
tax return.

Instructions for Form 4626 (2024)

If you have comments concerning the accuracy of these
time estimates or suggestions for making this form simpler,
we would be happy to hear from you. See the instructions for
the tax return with which this form is filed.

13