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On page 3, the following paragraph is added above “Statement of Rules Applied.”
Notice 2026-7 provides interim guidance regarding the application of the CAMT under sections 55, 56A, and 59. The interim guidance: (i) modifies certain interim guidance provided in Notice 2025-49; (ii) addresses an adjustment to AFSI for tax deductible repairs with respect to section 168 property; (iii) addresses an adjustment to AFSI for section 197 amortization attributable to certain intangibles acquired in certain transactions; (iv) addresses an adjustment to AFSI for amortization of domestic research or experimental expenditures; (v) addresses an adjustment to AFSI for certain production costs attributable to film, television, live theatrical, and sound recording productions; (vi) addresses an adjustment to AFSI for certain low acquisition cost tangible property treated as materials and supplies; (vii) clarifies the interim guidance for financially troubled companies provided in Notice 2025-46; (viii) modifies the anti-abuse rule in Proposed Regulations section 1.56A-4 that would apply to certain covered asset transactions; (ix) addresses certain CAMT consequences of transactions involving intangible property subject to section 367(d); and (x) provides the applicability dates and requirements for reliance. Notice 2026-7 also describes statements that must be attached to federal income tax returns for CAMT entities making certain AFSI adjustments provided in the interim guidance.