A Senate effort to reverse a Trump administration regulatory change projected to deliver more than $10 billion in tax relief to some of the nation’s most profitable corporations fell short Tuesday, as nearly all Republicans voted to block the measure.
The resolution, introduced under the Congressional Review Act by Senate Finance Committee Ranking Member Ron Wyden of Oregon and Sen. Angus King of Maine, failed by a vote of 47-51. The only Republican to vote in favor was Sen. Susan Collins of Maine, who recently confirmed she is running for another term.
The measure sought to overturn Internal Revenue Service Notice 2025-28, guidance that modifies how large corporations and private equity firms account for partnership income under the Corporate Alternative Minimum Tax, or CAMT. Lawmakers who backed the resolution argued the notice weakens implementation of the minimum tax and effectively creates a $10.3 billion break for some of the wealthiest corporations.
According to the Joint Committee on Taxation, the loophole embedded in the new regulations will cost taxpayers over $10 billion over a decade unless it is reversed. The notice allows large corporations and private equity firms to choose among six different methods for counting partnership income. Companies may select different methods across multiple partnerships they own, enabling them to reduce their tax liability.
The CAMT was enacted by Congress in 2022 as part of the Inflation Reduction Act. It requires corporations reporting more than $1 billion in profits to shareholders to pay at least 15 percent of those profits in taxes. The provision applies to approximately 150 of the country’s wealthiest corporations and took effect beginning in tax year 2023.
The minimum tax was passed after evidence showed that some highly profitable corporations were paying little or nothing in federal income taxes. From 2018 to 2020, 39 Fortune 500 companies generating $122 billion in profit paid $0 in federal income tax. During that same period, one of the most profitable companies in the United States secured a 4.3 percent effective tax rate on $43.4 billion in income, described as less than one-third of the rate paid by the average American taxpayer.
Wyden connected the IRS guidance to a broader pattern of corporate tax changes. “The ink is barely dry on the megabill Trump and Republicans passed to give $1 trillion in new tax breaks to giant corporations, and now his Treasury Department is throwing another $10 billion handout to the most profitable corporations in America,” Wyden said.
He added, “The pattern we’re seeing is that the Trump administration gives big corporations and ultra-wealthy donors whatever tax benefits they want the second they walk through the door at the Treasury Department, but that doesn’t mean the Senate has to allow this giveaway to happen. Stuffing $10 billion into the coffers of corporations that are already raking in enormous profits is indefensible at a time when so many Americans are getting battered by inflation and barely staying afloat.”
King framed the issue in terms of household economic pressures. “It’s downright unfair to give billions in tax relief to America’s most successful corporations when Maine people are struggling to afford their prescription drugs, childcare, and groceries,” King said.
He continued, “This Congressional Review Act (CRA) resolution would block the administration’s harmful tax policy that provides a loophole for corporations looking to skirt paying their taxes. This is a commonsense step toward a fairer tax policy that prioritizes people over profits and levels the playing field.”
Economic justice advocates also criticized the Senate vote. David Kass, executive director of Americans for Tax Fairness, said in a statement that “after passing historic tax giveaways for billionaires and big business through the One Big Beautiful Bill Act (OBBA), blowing up the deficit, and cutting billions from critical healthcare and nutrition programs to pay for it, Trump and his GOP allies in the Senate are taking every opportunity to ensure economic elites can avoid paying their fair share.”
Kass further stated, “This guidance would effectively circumvent Congress and create numerous opportunities for corporate tax evasion while increasing the deficit and national debt, thus creating more imbalance in a tax code that already favors the wealthy and large corporations.”
He concluded, “Sen. Wyden is right to lead the charge to stop this guidance—average Americans should not be forced to subsidize some of the most profitable companies on Earth.”
Matt Gardner, a senior fellow at the Institute on Taxation and Economic Policy, wrote in a Tuesday blog post that even if Congress had succeeded in reversing the rule, the president likely would have vetoed it. “even if lawmakers of both parties had sufficient backbone to retake the legislative power that the executive branch has usurped, President Trump would veto such a bill.”
Gardner argued the vote still produced useful information by triggering an official cost estimate. “But as a matter of educating lawmakers and the public, the recently rejected measure was a success given that tax legislation (such as this resolution) up for a vote in Congress usually gets an official budget score from Congress’ revenue estimators at the Joint Committee on Taxation,” he wrote. “And in this case, that reveals that this unilateral corporate tax cut from the Trump administration will cost $10 billion over a decade unless it is reversed.”
He added, “The Senate’s failure to ratify Wyden’s resolution may be only the opening salvo for members of Congress who want to retake the power given them under the Constitution to make tax law.” Gardner also wrote, “The regulation in question is not the first, and surely not the last, attempt by President Trump to unilaterally cut corporate taxes.”
With the resolution defeated, IRS Notice 2025-28 remains in effect, and the projected $10.3 billion in tax relief will move forward unless further legislative action is taken. Wyden described the stakes in fiscal and economic terms, stating, “Stuffing $10 billion into the coffers of corporations that are already raking in enormous profits is indefensible at a time when so many Americans are getting battered by inflation and barely staying afloat.”
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