Alternative Minimum Tax (AMT): AMTI, Exemptions & ISO Trap

Who Owes AMT in 2026  •  AMTI Computation  •  Preferences & Adjustments  •  ISO Exercise Danger  •  AMT Credit
IRC §55-59 Form 6251 Updated 2026
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The alternative minimum tax is a parallel tax system that adds back certain deductions and preferences to income, computes tax at a flat rate, and requires the taxpayer to pay whichever is higher - regular tax or AMT. TCJA dramatically reduced AMT exposure for most taxpayers by raising the exemption and phaseout thresholds significantly. In 2026, relatively few individuals owe AMT - but those who exercise incentive stock options, have large miscellaneous itemized deductions, or have certain preferences remain at real risk.

2026 AMT Key Numbers

Exemption: $140,200 (MFJ) / $90,100 (single) - inflation-adjusted annually

Exemption phaseout: Begins at $1,000,000 (MFJ) / $618,725 (single) - exemption reduced $0.25 per dollar above threshold

AMT rates: 26% on AMTI up to $244,500 / 28% above $244,500

AMT credit: Excess AMT paid over regular tax generates a minimum tax credit (MTC) under IRC §53, usable in future years when regular tax exceeds AMT

Who Actually Owes AMT in 2026

Before TCJA (2017), millions of middle-income taxpayers owed AMT each year - primarily because the exemption was not indexed for inflation. TCJA roughly doubled the exemption and indexed it going forward. OBBBA made those parameters permanent. As a result, the AMT in 2026 primarily affects:

Computing AMTI: The Step-by-Step Process

AMTI Computation - Form 6251
Start:Regular taxable incomeFrom Form 1040 before the standard or itemized deduction adjustment
+/-AMT adjustmentsAdd back certain deductions allowed for regular tax but disallowed for AMT
+AMT preferencesAdd specified preference items that are excluded or reduced for regular tax
=AMTI before exemption
-AMT exemption$140,200 MFJ / $90,100 single (2026), reduced above phaseout threshold
=Taxable excess
x26% / 28%26% on first $244,500; 28% above
-AMT foreign tax credit
=Tentative minimum tax (TMT)
AMT owed= TMT minus regular tax (if positive)

Key AMT Adjustments and Preferences

ItemAMT TreatmentRegular Tax Treatment
SALT deductionNot deductible for AMT (added back entirely)Deductible up to $40,000 cap (OBBBA)
Standard deductionNot deductible for AMT$30,000 MFJ / $15,000 single (2026)
Miscellaneous itemized deductionsNot deductible for AMTEliminated for regular tax by TCJA (so no longer a difference for most)
ISO exercise spreadPreference item - full spread added to AMTINo income recognized at exercise
Accelerated depreciation (personal property)Must use ADS (slower) depreciation; difference is an adjustmentMACRS or 100% bonus depreciation
Percentage depletionLimited to cost depletionPercentage depletion in excess of cost basis allowed
Private activity bond interestIncluded in AMTIExcluded from regular income
Qualified dividends and LTCGStill taxed at preferential rates (0%/15%/20%) for AMTSame preferential rates
SALT and standard deduction are the biggest changes post-TCJA. Before TCJA, taxpayers who itemized and deducted large state taxes faced AMT because SALT was an AMT adjustment. Now, SALT is already capped at $40,000 for regular tax purposes, and most people who might have faced AMT from SALT no longer do - the regular tax cap essentially pre-limits the deduction. The standard deduction is still an AMT adjustment but the high exemption means few people owe AMT because of it.

The ISO Exercise AMT Trap

The most dangerous AMT situation for individuals involves incentive stock options. When an employee exercises an ISO, no regular income tax is owed at exercise - but the entire spread (fair market value minus exercise price) is an AMT preference item added to AMTI. For employees at startups or high-growth companies with large ISO grants, exercising in a year when the stock is highly valued can generate hundreds of thousands of dollars of AMT preference income.

The trap: AMT owed without cash to pay it. An employee who exercises $2M of ISO spread in December owns stock that cannot immediately be sold (lockup, illiquidity, holding period requirements). AMT is due in April on the $2M preference. If the stock subsequently declines before the employee can sell - as happened during the 2000 and 2008 downturns - the AMT bill may exceed the value of the stock. The AMT credit helps long-term but does not solve the immediate cash flow problem. Model the AMT exposure before exercising large ISO grants, especially in concentrated, illiquid positions.

The AMT Credit: Getting the Money Back

AMT paid because of timing differences (like ISO exercise) generates a minimum tax credit (MTC) under IRC §53. The MTC can be used in future years when regular tax exceeds AMT - effectively recovering the AMT paid when the underlying stock is sold and the income is recognized for regular tax purposes. The MTC carries forward indefinitely. For ISO exercisers who hold and sell in a qualifying disposition, the AMT paid in the exercise year is generally recovered via the MTC in the sale year.

AMT for Corporations

TCJA eliminated the corporate AMT (which had been 20% on AMTI). The Inflation Reduction Act of 2022 (IRA) replaced it with a 15% Corporate Alternative Minimum Tax (CAMT) on Applicable Financial Statement Income (AFSI) - essentially adjusted book income - for corporations averaging more than $1 billion in AFSI over 3 years. This is a separate regime from the individual AMT and is reported on Form 4626.

For most businesses - S-corporations, partnerships, and C-corporations below the $1 billion threshold - the corporate AMT is not relevant. The individual AMT remains the concern for owners of pass-through entities with preference items flowing through to their returns.

Authority: IRC §55 (imposition of AMT - taxpayers pay the greater of regular tax or tentative minimum tax); IRC §55(b) (AMT rates - 26% on first $244,500 of taxable excess, 28% above); IRC §55(d) (exemption amounts - $140,200 MFJ, $90,100 single for 2026, indexed annually); IRC §55(d)(3) (exemption phaseout - $0.25 reduction per dollar above threshold); IRC §56 (AMT adjustments - SALT, standard deduction, accelerated depreciation, miscellaneous deductions); IRC §56(b)(1)(A)(ii) (SALT not deductible for AMT); IRC §57 (AMT preference items - ISO spread §57(a)(3), percentage depletion §57(a)(1), private activity bond interest §57(a)(5)); IRC §58 (denial of certain losses for AMT); IRC §59 (other definitions and special rules); IRC §53 (minimum tax credit - carryforward of AMT attributable to timing differences); IRC §422 (ISO exercise - §57(a)(3) cross-reference for AMT preference); Form 6251 (Alternative Minimum Tax - Individuals); TCJA P.L. 115-97 (2017) (doubled AMT exemption, raised phaseout thresholds, indexed going forward); OBBBA P.L. 119-21 (made TCJA AMT parameters permanent); IRA P.L. 117-169 (Corporate AMT - 15% on AFSI above $1B - Form 4626).
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