Senate rejects IRS corporate tax rollback in 47-51 vote

On February 10, 2026, the Senate voted 47-51 to reject S.J. Res. 95, a Congressional Review Act resolution that would have overturned IRS Notice 2025-28 — Treasury Department guidance that weakened the Corporate Alternative Minimum Tax (CAMT) by giving large corporations six different methods to calculate partnership income, letting them pick whichever method lowered their tax bill the most.

The CAMT was created by the Inflation Reduction Act of 2022 to require corporations reporting more than $1 billion in annual profits to their shareholders to pay at least 15% of those profits in federal income taxes. The Joint Committee on Taxation estimated the CAMT would generate $222.2 billion in revenue from 2023 through 2031, and it applies to roughly 150 of Americas wealthiest corporations.

IRS Notice 2025-28, issued July 29, 2025, introduced new elective methods for calculating adjusted financial statement income (AFSI) from partnership investments. In practice, this let multi-billion-dollar corporations and private equity firms choose one of six different accounting methods for each of the dozens or hundreds of partnerships they own — picking whichever method minimized their tax liability for each one.

The Joint Committee on Taxation scored the Treasury guidance as costing taxpayers $10.3 billion over ten years, meaning corporations subject to the CAMT would pay $10.3 billion less than Congress intended when it passed the Inflation Reduction Act.

Senator Ron Wyden (D-OR), the ranking member of the Senate Finance Committee, and Senator Angus King (I-ME) introduced the CRA disapproval resolution. On the Senate floor, Wyden said the Trump administration treats the U.S. Treasury Department like Make-A-Wish for corporations and private equity.

Senator SCSusan Collins (R-ME) was the only Republican to vote in favor of the resolution, crossing party lines to join all 46 Democrats and independents. Collins announced her reelection bid on the same day as the vote.

Treasury Secretary SBScott Bessent defended the guidance, calling the CAMT a flawed, partisan experiment hatched in the minds of liberal academics who lacked practical experience. Bessent said the Treasury was committed to restoring sanity to tax administration and keeping bureaucracy out of the way of job growth.

Notice 2025-28 was part of a broader pattern of Treasury actions weakening the CAMT. Earlier, Notice 2025-27 (June 2025) raised the safe harbor threshold from $500 million to $800 million, letting more corporations avoid CAMT entirely. Combined, these changes represented what the Center on Budget and Policy Priorities called a systematic regulatory assault on the corporate minimum tax.