Marc Gerson commented on the possibility of the IRS issuing a FAQ fact sheet to provide guidance on the new corporate alternative minimum tax (AMT). While FAQs have potential benefit for disseminating early corporate AMT guidance, the IRS and Treasury will want to carefully weigh the pros and cons of that approach, Gerson said. For one thing, the government is facing lots of regulatory authority challenges under the Administrative Procedure Act while also trying to be inclusive and transparent about this guidance, he said. Some short-term guidance on corporate merger issues and procedural problems, coupled with penalty relief, could ease the pressure the IRS and Treasury face to expedite corporate AMT regulations. However, he added, the more formal the guidance, the better.