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The corporate AMT: ‘Its own little tax system’

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There may be a surprise in store for some partnerships whose investors include an “applicable corporation” — particularly smaller ones.

Regulations for the corporate alternative minimum tax, proposed in September 2024, can affect a broad swath of partnerships, including smaller “mom and pop” partnerships. Under the proposed regulations from the Treasury Department, where an applicable corporation is invested in a partnership, the lower-tier partnership has the obligation to help the applicable corporation up the chain meet its actual CAMT filing requirements. 

“The CAMT, at the end of the day, is intended to target a few thousand corporations who will actually be CAMT taxpayers,” said Cameron Johnson, partnerships leader with the Washington tax council practice of Top 10 Firm Baker Tilly. “These corporations are invested in joint ventures and partnerships, which could range from very large partnerships to your mom and pops of the world down the chain. They have to provide a lot of information up the chain to the ultimate taxpaying corporation. Then that corporation can just determine its distributive share of the lower-tier partnerships’ adjusted financial statement income.”

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Although the CAMT is intended for a limited number of targets, there are probably hundreds of thousands of partnerships out there that will have to comply with providing all of the information, according to Johnson. 

“It’s extremely detailed, complex information,” he said. “Where these partnerships historically have maintained two sets of books to comply with their federal tax filing requirements, they are now going to have to maintain effectively a third set of books for CAMT purposes. They have to dig into financial statement information and make a whole series of adjustments at the partnership level that touch on all areas of tax, ranging from international issues, cost recovery, credits and incentives — all these different adjustments that have to be made and analyzed to flow up to these corporations so that the corporation can calculate and pay whatever CAMT liability they may have.”

Johnson predicts that many partnerships will see the word “CAMT” and believe it’s not applicable to them. “But the unfortunate fact of the matter is that it is applicable, and that these partnerships will get requests from these upper-tier corporations to provide that information that ultimately has to make its way up the chain.”

“This is what we’ve been digging through to bring our local offices and our clients up to speed. These proposed regulations are the gift that keeps on giving all year round,” he said. “Every time we get into them we find more and more, and what we thought was just a few pages of data keeps ballooning. CAMT itself is really its own little tax system that incorporates topics from everywhere in  the Tax Code. It takes a lot of work to get all of those to play nice with each other.”

The Treasury Department had a choice to make between a top-down and bottom-up approach to determine a partner’s distributive share. It chose the bottom-up approach, which places the onus on the partnerships at the bottom of the chain. The regs themselves are more than 600 pages, and took more than two years to develop.

Although the huge partnerships of the world will have little trouble understanding and complying with the regs, Johnson believes the administrative burden will be extremely troubling for the small partnerships to deal with.  

“As of now, the proposed regulations are in the comment stage,” he said. It would make sense for some kind of small taxpayer safe harbor or something along those lines to be considered, but as it stands now there is no real differentiation between the smallest of the small partnerships down the chain versus the massive partnerships. The huge partnerships are more equipped to deal with these types of scenarios, but even at their level it’s still a big ask to maintain all of this new data and to analyze it and run it up the chain.”

The statutory scheme is a novel concept in that the starting point is the financial statement, rather than taxable income, he observed.

“As a whole, the statutory scheme is a little vague, and it leaves a lot to Treasury to fill in the details, and that’s what the proposed regulations have done. They gave a bit of a blank slate to Treasury to fill in the gaps, which they pushed down from huge, sophisticated corporations into the presumably smaller partnerships down the chain. So it really puts a lot of the burden down the chain rather than on the corporation itself in complying with the proposed regulations.”

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SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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