I need to understand the applicability of the Corporate Alternative Minimum Tax (CAMT) and the Base Erosion and Anti-Abuse Tax (BEAT) for corporations in the United States. Please explain what makes a corporation 'applicable' for CAMT, including the AFSI thresholds for both general and foreign-parented multinational groups. For BEAT, identify the two main criteria that trigger its application. Finally, provide the names and titles of the direct contacts for US tax inquiries listed on this page.
Navigate to 'https://taxsummaries.pwc.com/united-states/corporate/taxes-on-corporate-income'. Locate the 'Corporate alternative minimum tax (CAMT)' section. Identify the general AFSI threshold for a corporation to be considered 'applicable' for CAMT. Identify the two-part test and associated AFSI thresholds for a corporation that is a member of a foreign-parented multinational group to be considered 'applicable' for CAMT. Locate the 'Base erosion and anti-abuse tax (BEAT)' section. Identify the two main criteria (gross receipts and base-eroding payments percentage) that trigger the application of BEAT. Locate the 'United States contacts' section. Identify the names and titles of the direct contacts for US tax inquiries. Synthesize all gathered information into a concise answer.
The agent successfully navigates to the United States tax summary page. The agent accurately states that a corporation is generally 'applicable' for CAMT if its average annual AFSI over a three-tax-year period exceeds USD 1 billion. The agent accurately states the two-part test for foreign-parented multinational groups for CAMT applicability: 1) three-year average AFSI of all group members exceeds USD 1 billion, AND 2) three-year average AFSI of US members and certain related entities exceeds USD 100 million. The agent accurately states the two main criteria for BEAT application: 1) average annual gross receipts for the three-year period ending with the preceding tax year of at least USD 500 million, AND 2) certain base-eroding payments to related foreign persons during the tax year of 3% (or 2% for certain banks and securities dealers) or more of all their deductible expenses. The agent identifies 'Krishnan Chandrasekhar, US Tax Leader, PwC US' and 'Ed Geils, US Tax Knowledge Management Leader, PwC US' as direct contacts for US tax inquiries.