H.R. 2872 — RESILIENCE Act of 2025

This section revises the depreciation adjustment to adjusted financial statement income (AFSI)—the base for the corporate alternative minimum tax (CAMT)—to (1) reduce AFSI by depreciation deductions allowed under section 167 and applicable public utility repair and maintenance deductions allowed under section 162, in each case with respect to depreciable tangible property and to the extent allowed in computing taxable income, and (2) adjust AFSI to disregard any depreciation expense for such property reported on the taxpayer’s applicable financial statement (AFS). Applicable public utility repair and maintenance deductions are section 162 deductions for expenditures incurred by the taxpayer on public utility property (i.e., property used predominantly in furnishing or sale of electrical energy, water, sewage disposal services, gas, or steam through a local distribution system, if owned by the taxpayer) that are treated as depreciation expense on the taxpayer’s AFS. (Thus, this aligns AFSI with tax treatment for public utility repairs and maintenance expensed for tax purposes but capitalized on financial statements.) The changes apply to taxable years beginning after December 31, 2024.