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 Scrap IRS Rule Simplifying Corporate Minimum Tax for Partnerships

This Joint Resolution is a direct legislative challenge to the Internal Revenue Service (IRS), specifically targeting a piece of guidance called “Interim Guidance Simplifying Application of the Corporate Alternative Minimum Tax to Partnerships.” In plain English, this resolution uses a special legislative tool—the Congressional Review Act (CRA)—to tell the IRS that their attempt to simplify how certain large businesses (partnerships) calculate a specific tax (the Corporate Alternative Minimum Tax, or CAMT) is being rejected. If this resolution passes, the IRS rule is nullified and officially has “no force or effect.”

The Tax Jargon Breakdown

To understand why Congress is doing this, let’s quickly define the players. The CAMT is a new 15% minimum tax on the financial statement income of large corporations, generally those reporting over $1 billion in average annual income. The IRS issued interim guidance to clarify how this tax applies to partnerships, which are common business structures but aren't traditional corporations. The guidance was meant to help these complex entities figure out their tax obligations under the new CAMT rules. This resolution effectively slams the brakes on that specific simplification effort, forcing the IRS to go back to the drawing board.

Why This Matters for the Real World

This isn't about raising or lowering your personal income tax, but it does affect the regulatory landscape for large-scale business operations. The immediate impact is primarily procedural: Congress is exercising its power under the CRA to overturn an administrative rule. For the tax professionals and large partnerships affected, this means the specific simplification provided by the IRS guidance is off the table. If that guidance was making compliance easier, its removal means increased complexity or uncertainty until the IRS issues new instructions.

Think of it like this: the IRS gave out a shortcut for filling out a massive, complicated form. Now, Congress is stepping in and saying, "Nope, that shortcut is invalid. You have to wait for us to tell you the right way, or figure it out the hard way for now." While this is a check on the regulatory power of the IRS, it also creates a vacuum for those businesses trying to comply with the new CAMT rules. The groups most affected are the IRS itself, whose authority is being challenged, and the large partnerships that now lose a piece of interim clarity they might have been relying on.