PolicyBrief
S.J.RES. 95
119th CongressNov 18th 2025
A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to "Interim Guidance Simplifying Application of the Corporate Alternative Minimum Tax to Partnerships".
IN COMMITTEE

This joint resolution disapproves the IRS rule simplifying the application of the Corporate Alternative Minimum Tax to partnerships.

Ron Wyden
D

Ron Wyden

Senator

OR

LEGISLATION

Congress Moves to Void IRS Rule Simplifying Corporate Minimum Tax for Partnerships

This joint resolution is a procedural move by Congress to completely nullify a specific rule recently issued by the Internal Revenue Service (IRS). The rule in question is the “Interim Guidance Simplifying Application of the Corporate Alternative Minimum Tax to Partnerships.” If this resolution passes, that IRS guidance—which was designed to make it easier for large partnerships to figure out how the new Corporate Alternative Minimum Tax (CAMT) applies to them—will be immediately struck down and have no legal effect.

The CAMT Tax Tango

To understand why this matters, you need to know about the Corporate Alternative Minimum Tax (CAMT). This is a 15% minimum tax introduced in 2022 that applies to large corporations reporting over $1 billion in profits. The IRS guidance that Congress wants to void was essentially the IRS trying to write the instruction manual for how the CAMT should handle partnerships—complex entities often used in private equity, real estate, and other high-level finance. The IRS was trying to simplify the calculation, likely because the initial law left some gaps about how to treat partnership income for this new corporate tax.

Striking Down the Rulebook

This resolution uses a mechanism called the Congressional Review Act (CRA). Think of the CRA as Congress having a veto pen over agency rules. By using this resolution, Congress is saying, "IRS, we disagree with your interpretation or simplification, and we are voiding your rule." The bill is short and direct: it states that the IRS rule "shall have no force or effect." For the everyday person, this is a classic example of Congress using its oversight power to push back on the executive branch (the IRS, in this case) when it feels the agency overstepped its bounds or got the implementation wrong. It’s a turf war over who gets to write the tax rules.

Who Feels the Change?

If this resolution succeeds, the immediate impact is felt by the IRS and the large partnerships it was trying to guide. The IRS loses its attempt at simplifying the process, meaning it has to go back to the drawing board to figure out how these partnerships should calculate the CAMT. For the tax world, this creates temporary uncertainty. Tax professionals and the partnerships they serve now have to navigate the initial, potentially more complex, statutory language without the benefit of the IRS’s simplification. While the resolution itself doesn't change the tax rate or who pays the tax, it changes the how—and in tax law, the 'how' is everything. It makes compliance potentially harder for those large entities that were relying on the now-voided guidance.