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Accounting

Tax Strategy: IRS issues guidance on OBBBA deductions and related payroll changes

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Since the enactment of H.R. 1, the One Big Beautiful Bill Act, the Internal Revenue Service has announced that it will not be updating 2025 tax forms such as the W-2 and 1099s to reflect OBBBA changes impacting 2025 tax returns. 

Instead, it intends to provide guidance on how to implement the OBBBA with the existing forms. 2025 guidance is needed on how to reflect tips that qualify for the tip deduction on the 2025 tax return. Guidance is also needed on how to reflect qualifying overtime to qualify for the overtime deduction. These may require alteration of payroll practices. Guidance may also be needed on Trump Accounts and the possibility that employers may want to make contributions to the accounts of employees’ children.

The IRS has released the draft version of a new Form 1040 Schedule 1-A, which discusses the calculation of the new below-the-line deductions for tips, overtime, car loan interest, and seniors. It has also released a draft Form 1040 for 2025. The IRS also released proposed regulations with respect to the tips deduction. Although the IRS is not planning to revise the 2025 version of Form W-2, it has issued a draft version of the 2026 Form W-2.

Schedule 1-A

A new draft Schedule 1-A is to be utilized in the calculation of each of the four new below-the-line deductions on the schedule. Part I of draft Schedule 1-A is for insertion of modified adjusted gross income, which will be utilized in calculating the impact of the phase-outs of the deductions.

Tip deduction

Part II of the schedule is for the calculation of the qualified tip income deduction. Qualified tip income for an employee is to be reported on Form W-2, Box 7, only if income reported on Form W-2 Box 5 is $176,000 or less. Qualified tips may also be reported on Form 4137, Line 1(c) for Social Security and Medicare tax on unreported tip income. 

It does not appear that draft Form 4137 has yet been updated to reflect this information on Line 1(c). The IRS has issued a list of 68 occupations, with occupation codes, that may have qualifying tip income, while also indicating that the list may be further modified.

 Schedule 1-A instructions, which have not yet been issued as of this writing, are to address situations with more than one employer. Another line is to include qualified tips from a trade or business, which are to be reported on Form 1099-NEC, Box 1, Form 1099-MISC, Box 3, or Form 1099-K. The qualified tips may not exceed the net profit from the trade or business, and instructions are to address situations with more than one trade or business.

The total of these sums is then to be compared to the $25,000 limit on deductible qualified tips. MAGI is then compared to the phase-out range of $150,000 ($300,000 for joint filers) for the final deduction calculation.

The proposed regulations on the tip income deduction include a discussion of what constitutes tips paid in cash or cash equivalents; that the tips must be received from customers or through a mandatory or voluntary tips sharing arrangement; that the tips must be voluntary and not subject to negotiation; and may not be a service charge unless there is an option to modify or disregard the charge.

The regulations also discuss categories of workers not eligible for the tip deduction, including specialized services trades or businesses, where the business depends primarily on the reputation of its owners or employees, performing artists, and athletes. It also excludes illegal activity, prostitution, and pornographic activity, although working for a business that violates the law in some other respects may not be disqualifying.

Guidance is still to be forthcoming for 2025 where tip and non-tip income are not stated separately. Employers and their payroll administrators will want to start looking at segregating qualifying tips from other tips. Consideration might be given to removing any fixed service charges that will not qualify for the tip deduction. Note should also be taken of which occupation codes qualify for the deduction.

Overtime

Part III of Schedule 1-A addresses overtime. Qualified overtime compensation is to be inserted from Form W-2, Box 1, Form 1099-NEC, Box 1, or Form 1099-MISC, box 3. 

The instructions to be issued will clarify how to handle situations where the required information does not appear on those forms for 2025 and how to determine what constitutes qualified overtime. These sums are then compared to the deduction limit of $12,500 ($25,000 for joint filers). Then MAGI is compared to the phase-out range of $150,000 ($300,000 for joint filers), with the calculation resulting in the qualified overtime deduction.

Employers should take steps to try to identify and segregate qualifying overtime from non-qualifying overtime. Overtime is more likely to qualify if it is being paid in accordance with Fair Labor Standards requirements.

Car loan interest

Part IV of Schedule 1-A addresses the new car loan interest deduction. Schedule 1-A refers to the instructions for determining qualified passenger vehicle loan interest, with interest on not only Schedule 1-A but also Schedules C, E or F. Those interest amounts are to be supported by third-party reporting by the lender. 

Vehicle identification numbers for up to two vehicles can be listed on the schedule, with the instructions to address more than two vehicles. The total interest is then compared to the $10,000 deduction limit. Next, MAGI is compared to the phase-out limit of $100,000 ($200,000 for joint filers) for calculation of the final deduction.

This deduction is less likely to impact payroll. Care should be taken to make sure that the new vehicle qualifies for the deduction, such as a VIN beginning with 1, 4 or 5 indicating assembly in the U.S. Commercial vehicles do not qualify for the deduction — it must be for personal use.

The Senior Deduction

Part V of Schedule 1-A addresses the $6,000 senior deduction, which also does not have payroll impact. The senior deduction is only available if the taxpayer and spouse have valid Social Security numbers and, if married, a joint return is filed. MAGI is compared to the phase-out limits of $75,000 ($150,000 for joint filers). The amount by which MAGI exceeds the phase-out amount, if any, is multiplied by 6%, and that amount is subtracted from the $6,000 limit. This sum is then included as a below-the-line deduction if the taxpayer has a valid Social Security number and was born before Jan. 2, 1961. It is also included again if the spouse has a valid Social Security number and was born before Jan. 2, 1961.

Part VI of Schedule 1-A then adds the totals from the four deductions, which is then entered on Form 1040, line 13b or 1040NR line 13c.

Trump Accounts

Employers should also anticipate possible involvement with the set up of Trump Accounts. The accounts are available to children born starting in 2025; however, due to administrative issues, the accounts cannot be set up until Jan. 1, 2026. 

Of the $5,000 in annual funding of the accounts, up to $2,500 may come from employers. Another $1,000 in seed money will come from the federal government. Employers will need to decide if they want to participate in funding Trump Accounts and set up the payroll procedures to do so by the end of 2025.

2026 Draft Form W-2

While the IRS has announced that they will not update the 2025 Form W-2, the agency has issued a draft 2026 Form W-2. Box 14 is divided into Box 14a and 14b. Box 14a is to be used for various items such as state disability insurance taxes withholding, union dues, uniform payments, health insurance premiums deducted, non-taxable income, or educational assistance payments. Box 14b is to be used for reporting the taxpayer’s tip occupation code. Box 12 has several new codes: TA for employer contributions to Trump Accounts, TP for qualified tips, and TT for qualified overtime compensation. 

Additional IRS guidance will direct employers as to how to report these items on the 2025 Form W-2.

Summary

Employers, payroll administrators, and self-employed persons should begin to take steps to identify qualifying tips and overtime and to be able to supply the information to the IRS necessary to support tip and overtime deductions and any employer contributions to Trump Accounts. 

At this point in time, we still await further guidance on these below-the-line deductions and guidance on qualified tip and overtime reporting. Hopefully, some of this additional guidance will be forthcoming in the near future.

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Accounting

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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Accounting

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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