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".

WHAT HAPPENED: On February 10, 2026, the Senate voted 47-51 to reject a motion to proceed on SJRES95, a joint resolution under the Congressional Review Act that would have disapproved IRS Notice 2025-28. Notice 2025-28 provides interim guidance simplifying the application of the Corporate Alternative Minimum Tax (CAMT) to partnerships. With the resolution's failure, the IRS guidance remains legally in effect, and the CAMT treatment of partnerships continues unchanged. The bill was introduced by Sen. Wyden (D-OR) with 3 cosponsors and was originally referred to the Finance Committee before being discharged by petition.

THE MONEY TRAIL: There is no monetary allocation in this resolution. SJRES95 is a disapproval resolution under the CRA — it does not authorize or appropriate any funds. The financial effect is purely regulatory: the existing IRS Notice 2025-28 guidance remains operative, meaning partnerships continue to follow the simplified CAMT application rules outlined in that notice. No taxpayer dollars are moved, no new programs are created, and no contracts are awarded.

STRUCTURAL WINNERS AND LOSERS: Because the vote simply preserves the regulatory status quo, there are no direct winners or losers among publicly traded companies. The CAMT was established by the Inflation Reduction Act (2022) and applies generally to corporations with average annual adjusted financial statement income exceeding $1 billion. Notice 2025-28 provides simplified safe harbors and computational methods for applying the CAMT to partnerships (including publicly traded partnerships, MLPs, and private equity structures). The guidance being maintained provides regulatory certainty for partnerships with corporate partners but does not create a meaningful competitive advantage or disadvantage for any specific publicly traded company. Large partnerships affected by CAMT are typically private structures (private equity, hedge funds, family offices) rather than public corporations.

COMPETITIVE LANDSCAPE: The only entities with exposure are publicly traded partnerships (PTPs) and master limited partnerships (MLPs) that have corporate partners subject to CAMT. However, the IRS guidance preserved by this vote is simplifying, not punitive — it reduces administrative burden. No public company's revenue, margins, or competitive position is materially altered by this outcome. No real market data is available.

TIMELINE: This bill is effectively dead for the 119th Congress. No further legislative action is expected on this specific CRA resolution. The IRS guidance remains in effect unless the IRS itself revokes or modifies it, or Congress passes a separate bill changing the CAMT statute.