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for corporate taxpayers and subjected them to AMT. Congress also
altered the computation of AMTI by providing for differences
regarding when items of income or deductions are taken into
account in computing taxable income and AMTI. The post-1986 AMT
rules, sections 55-59, were enacted to achieve one overriding
objective: to establish a floor for tax liability, so that a
taxpayer pays some tax regardless of the tax breaks otherwise
available to him under the regular tax system. S. Rept. 99-313,
supra at 518, 1986-3 C.B. (Vol. 3) at 518. The AMT rules
accomplish this goal by eliminating favorable treatment to
certain items that are treated favorably for purposes of the
regular tax (tax preference items). Secs. 55(b)(2)(B), 57(a).
The legislative history under the 1986 Act states explicitly
that the computation of a corporation’s AMTI begins with taxable
income and that any adjustments required by the AMT regime are
made from there. The report of the House Ways and Means
Committee, for example, explains clearly and unambiguously that
the starting point for computing a corporation’s AMTI is “taxable
income”. The report states:
Explanation of Provisions
1. Overview
The bill repeals the present law add-on minimum
tax for corporations beginning in 1986, creates a new
alternative minimum tax on corporations, and expands
the alternative minimum tax on individuals.
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