Todd B. Reinstein, a tax partner with Pepper Hamilton, was quoted in the January 8, 2019 Tax Notes Today article, "OMB Reverses IRS’s Stance on Sequestering AMT Credits."
Even though the sequestration percentage is low, the OMB’s decision will have a “significant positive effect” on taxpayers with hundreds of millions of dollars in AMT credit carryovers, Todd B. Reinstein of Pepper Hamilton LLP told Tax Notes. That’s great news for those that had assumed that the refundable credits would be subject to the sequestration amount, he said.
Although the OMB has settled the sequestration question, an issue remains concerning whether the refundable AMT credits will be subject to limitation rules following an ownership change under sections 382 and 383, Reinstein said. Section 383 limits AMT credits, but the IRS hasn’t addressed whether those limitations apply to refundable credits, he added.
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