As companies assess the favorable corporate tax changes introduced by the One Big Beautiful Bill Act, some may find an unwelcome surprise: the same provisions that reduce taxable income may increase exposure to the corporate alternative minimum tax (CAMT). The OBBBA’s expensing benefits and extended credits from the Tax Cuts and Jobs Act can generate cash tax savings, but they do not reduce adjusted financial statement income. As a result, even when regular tax liability decreases, CAMT liability may still arise. Key areas where this tension is most pronounced include the treatment of research and experimental  expenditures under section 174, the interest limitation under section 163(j), and the newly defined foreign-derived deduction-eligible income. How should corporations approach planning when statutory incentives and CAMT rules conflict? What does this dynamic suggest for future legislative or regulatory responses? 

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Cara Griffith
President and CEO, Tax Analysts

As the moderator for our Taxing Issues webinars, Cara objectively analyzes issues and asks probing questions that challenge panelists to explain and defend their positions.

When she’s not moderating Taxing Issues webinars, Cara provides strategic oversight for Tax Analysts. She has led efforts to improve the Tax Notes suite of products and to aggressively pursue transparency in the administration of tax systems. Previously, Cara managed the editorial department, including the flagship daily news publications and weekly magazines. She has written for a broad range of tax policy publications, including Tax Notes State, The Tax Adviser, The Hedge Fund Law Report, and The Hill. She regularly speaks at tax conferences and other events, discussing a variety of technical tax issues as well as the need for transparency in tax administration.

Cara has a BA in political science and a BA in international studies from the University of Evansville and a JD from the George Washington University Law School.

Monisha Santamaria
Principal in KPMG's Washington National Tax practice

Monisha Santamaria joined KPMG as a principal in the firm’s Washington National Tax practice. Previously, Monisha served as a legislation counsel for the Joint Committee on Taxation.

Before that, Monisha was a senior manager in the national tax department of another Big Four firm, advising clients on a wide range of U.S. federal income tax issues affecting domestic and foreign partnerships. Earlier in her career, she worked as a tax associate at Skadden, Arps, Slate, Meagher & Flom LLP, primarily counseling multinational corporations on the U.S. federal income tax aspects of joint ventures, mergers, acquisitions, and divestitures, and as a tax planning associate at Bingham McCutchen LLP, chiefly serving Fortune 50, financial sector, and energy industry clients.
Monisha serves as a vice chair of the American Bar Association Section of Taxation’s Partnership Committee. She previously taught an advanced partnership tax course at the Loyola Law School and has spoken and published extensively on a variety of tax law issues. Monisha has been recognized as one of the top lawyers under 40 by the American Bar Association.

Monisha holds a JD from Stanford Law School. She earned a master’s degree in history and a BA, summa cum laude, in history from Tulane University.

Deborah Tarwasokono
Attorney-adviser at the Treasury Office of Tax Policy

Deborah Tarwasokono is an attorney-adviser in the Treasury Office of Tax Policy, where she specializes in international tax, with a special focus on foreign tax credits, the corporate alternative minimum tax, dual consolidated losses, and the One Big Beautiful Bill Act. She also serves as a U.S. delegate to the OECD’s Working Party 11.

Previously, Tarwasokono worked in the international tax and transactions services group of EY’s National Tax Department. She received her LLM in taxation from Georgetown University Law Center. 
 

Miles Johnson
Senior Attorney Advisor

Miles Johnson is a senior attorney-adviser at the Tax Law Center at NYU Law. He focuses primarily on tax and policy issues involving partnerships and other passthrough entities. Previously, he was a partner in the tax group of Kirkland & Ellis LLP, where he worked on a wide range of complex transactions.

Johnson is admitted to practice law in Illinois and Wisconsin. He has a JD from the University of Chicago Law School, where he served as an editor of the Chicago Journal of International Law. He holds a BA in English and philosophy from the University of Wisconsin-Madison.

Wade Sutton
International Tax Leader, Washington National Tax Office at PwC

Wade Sutton leads the international tax group in PwC’s Washington National Tax Services practice.  He specializes in international and mergers and acquisitions tax and has significant experience with cross-border acquisitions, divestitures, financing, and restructurings.

Previously, Sutton served as the deputy international tax counsel in Treasury’s Office of Tax Policy. There, he worked closely with Congress, foreign tax administrators, the IRS, and stakeholders to shape international tax policy, particularly in the implementation of the Tax Cuts and Jobs Act and the design of the Biden administration’s green books  and legislative proposals.  

Sutton is a member of the New York State Bar Association Tax Section’s executive committee and a co-chair of the section’s Inbound U.S. Activities for Foreign Taxpayers Committee. He is a member of the New York and District of Columbia bars. He has a BA in economics and philosophy from Washington University in St. Louis and a JD from Vanderbilt University Law School.