US Federal Senate Bill SJR95

US Federal 2025-2026 Regular Session

• Introduced: 2/10/26
• Introduced: 11/18/25
• Refer: 11/18/25

Caption

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".

Summary

S.J.Res. 95 is a congressional disapproval resolution under the Congressional Review Act. It would nullify IRS Notice 2025-28, titled “Interim Guidance Simplifying Application of the Corporate Alternative Minimum Tax to Partnerships,” and prevent that guidance from having any force or effect. In practical terms, the resolution does not itself create a new tax rule; instead, it seeks to overturn an IRS interpretive action related to how the corporate alternative minimum tax (CAMT) applies to partnerships. The measure targets federal tax administration and would affect the IRS’s ability to use the challenged guidance when applying CAMT to partnership structures. If enacted, it would remove the interim guidance from operation and could leave taxpayers and practitioners to rely on other existing statutory or regulatory authorities while Congress or the IRS determines a different approach. The bill’s impact is therefore centered on tax compliance, partnership taxation, and corporate minimum tax enforcement rather than on broader state law changes.

Impact

The resolution would have no direct effect on state statutes, but it would alter federal tax guidance governing partnerships and the corporate alternative minimum tax. By disapproving IRS Notice 2025-28, it would eliminate the agency’s interim simplification framework and could create uncertainty for partnerships, corporate taxpayers, and tax advisors regarding CAMT calculations and reporting until replacement guidance or legislation is issued.

Sentiment

The available voting history suggests the measure was controversial and did not advance easily: the Senate rejected a motion to proceed by a 47-51 vote. The bill was introduced by Senator Wyden with bipartisan cosponsors King and Peters, indicating some cross-party interest in the issue, but the floor vote shows insufficient support to move forward. No committee transcript is available, so the broader discussion appears to have centered on the tax policy merits of the IRS guidance rather than on unrelated issues.

Contention

The main point of contention is whether the IRS should be allowed to keep its interim guidance simplifying the application of the corporate alternative minimum tax to partnerships. Supporters of disapproval likely view the notice as an overreach, an improper shortcut, or a rule that should be withdrawn and reconsidered through a more formal process. Opponents likely see the guidance as a practical administrative tool that helps taxpayers comply with a complex tax regime. The disagreement is therefore between those favoring congressional rejection of the IRS approach and those favoring the agency’s attempt to simplify CAMT administration.