![]() ![]() ``(I) section 52(a) shall be applied by substituting ![]() ``(ii) Modifications.-For purposes of this subparagraph. Modifications described in clause (ii)) shall be treated asĪdjusted financial statement income of such corporation, andĪdjusted financial statement income of such corporation shallīe determined without regard to paragraphs (2)(D)(i) and (11) Subsection (a) or (b) of section 52 (determined with the Treated as a single employer with such corporation under Paragraph, all adjusted financial statement income of persons Whether a corporation is an applicable corporation under this ``(i) In general.-Solely for purposes of determining ``(D) Special rules for determining applicable corporation The preceding sentence shall not apply to any corporation if,Īfter the Secretary makes the determination described inĬlause (ii), such corporation meets the average annualįor any taxable year beginning after the first taxable year ``(ii) the Secretary determines that it would not beĪppropriate to continue to treat such corporation as an Which the corporation does not meet the average annualĪdjusted financial statement income test of subparagraph (B), Taxable years, including the most recent taxable year, in The facts and circumstances of the taxpayer) of consecutive Secretary and which shall, as appropriate, take into account ``(II) has a specified number (to be determined by the Term `applicable corporation' shall not include anyĬorporation which otherwise meets the requirements of ``(C) Exception.-Notwithstanding subparagraph (A), the Income of such corporation (determined without regard to theĪpplication of paragraph (2) and without regard to sectionĥ6A(d)) for the 3-taxable-year-period ending with such ``(II) the average annual adjusted financial statement ``(I) the corporation meets the requirements of clause (i)įor such taxable year (determined after the application of (2), such corporation meets the average annual adjustedįinancial statement income test for a taxable year if. ``(ii) in the case of a corporation described in paragraph The 3-taxable-year period ending with such taxable year ``(i) a corporation meets the average annual adjustedįinancial statement income test for a taxable year if theĪverage annual adjusted financial statement income of suchĬorporation (determined without regard to section 56A(d)) for ``(B) Average annual adjusted financial statement income ``(i) are prior to such taxable year, and With respect to any taxable year, any corporation (other thanĪn S corporation, a regulated investment company, or a realĮstate investment trust) which meets the average annualĪdjusted financial statement income test of subparagraph (B) ``(A) In general.-The term `applicable corporation' means, ``(k) Applicable Corporation.-For purposes of this part. (2) Applicable corporation.-Section 59 is amended byĪdding at the end the following new subsection: Tax for the taxable year shall be zero.''. Which is not an applicable corporation, the tentative minimum ![]() ``(B) Other corporations.-In the case of any corporation ``(ii) the corporate AMT foreign tax credit for the taxable ``(i) 15 percent of the adjusted financial statement incomeįor the taxable year (as determined under section 56A), over ``(A) Applicable corporations.-In the case of anĪpplicable corporation, the tentative minimum tax for the (1) In general.-Paragraph (2) of section 55(b) is amended Other provision of the Internal Revenue Code of 1986. Reference shall be considered to be made to a section or Subtitle an amendment or repeal is expressed in terms of anĪmendment to, or repeal of, a section or other provision, the This Act may be cited as the ``Inflation Reduction Act ofĮxcept as otherwise expressly provided, whenever in this Strike all after the enacting clause and insert the The senior assistant legislative clerk read as follows: Modified, with the changes at the desk, and I ask that it be reported (Purpose: In the nature of a substitute.) 5376) to provide for reconciliation pursuant The clerk will report the bill by title.Ī bill ( H.R. For complete and accurate display of this text, see the PDF.įrom the Congressional Record Online through the Government Publishing Office [INFLATION REDUCTION ACT OF 2022 Formatting necessary for an accurate reading of this text may be shown by tags (e.g., or ) or may be missing from this TXT display. ![]()
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