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Corporate AMT rules bring complications

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The Internal Revenue Service and the Treasury Department issued proposed regulations last month offering guidance on the corporate alternative minimum tax on companies with over $1 billion in income, but those rules could impact much smaller companies as well.

The CAMT was part of the Inflation Reduction Act of 2022 with the goal of ensuring billion-dollar corporations pay more in taxes. However, the draft rules have provoked pushback, not least because of their complexities. 

“The regulations are really complex in all the various aspects,” said David Strong, a partner in the tax services group at Crowe in Grand Rapids, Michigan. Among the complicating factors is depreciation. 

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The U.S. Treasury building in Washington, D.C.

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“Probably the one that impacts a lot of companies are going to be depreciation adjustments, where it’s viewed as a favorable type of approach,” said Strong. “You generally would add back your book depreciation to your financial statement income and take a deduction for your tax depreciation. In years where companies are taking the benefit of bonus depreciation, it certainly goes to reduce your adjusted financial statement income in determining, number one, if you’re subject to the corporate alternative minimum tax, or secondarily in computing the tax itself. But if you take a look at just those rules, they’re fairly complex in how you go about computing that adjustment. Generally you have to track through [whether] you are taking impairment losses for financial statement purposes that effectively get added back for computing your corporate AMT, and then tracking the basis difference, both from a financial statement perspective and a tax perspective.”

He expects the IRS and the Treasury to be inundated with comments from tax practitioners, corporations, and other groups ahead of a scheduled public hearing in January.

“The mindset is that it’s a lot of larger companies that are going to have sophisticated tax departments [with] people that can address some of these complex issues,” said Strong. “But I think the fallout is that we take a look at one of the aspects of the adjustment to your financial statement income deals with partnerships. Generally, if I’m a partner in a partnership, and I include that partnership income in my financial statement income, I need to make an adjustment for whatever my distributive share of the partnership’s adjusted financial statement income needs to be adjusted in, let’s say, the corporate entity’s financial statement income. That calculation generally is pushed to the partnership. That’s probably one of the areas from my client base that’s been impacted the most. If I have an investment partnership where I have a corporate entity that could be subject to the alternative minimum tax, they’re requesting that the partnership provide them with their distributed share of financial statement income. What that does is it effectively takes all the rules that apply to these larger companies and applies those to the partnership, because the partnership has to go through, as if it were that corporate entity, and give its adjusted financial statement income in order to provide that information to its partner that would be subject to the tax.”

Some of the partnerships are investment funds that have invested in the billion-dollar companies, he noted.

“The rub is those complex rules now need to be applied by smaller entities in order to provide the corporate entity that’s a partner in this partnership the requisite information they need in order to compute their corporate AMT,” said Strong.

It can get even more complicated with a tiered partnership. “The lower-tier company could be a corporation, or it could be another partnership,” said Strong. “If it’s another partnership, you have a second layer of having to do this computation. So the lower-tier partnership would have to go through and compute its AFSI, the adjusted financial statement income, and report that to the upper tier partnership, and then the upper tier partnership provides that information to the corporate entity. It can get fairly complex for companies that generally are much smaller than those that are paying the tax.”

The outcome may depend on the November election contest between Vice President Kamala Harris and former President Donald Trump. “If Harris wins the presidency, I think the shift there is to keep the corporate alternative minimum tax in place, but increase the rate from its current 15% to 21%,” said Strong. “If that’s the case, then the rules will be in place for a longer period of time.”

If Trump wins, he has expressed interest in eliminating the Inflation Reduction Act and lowering the corporate tax rate further. “The main focus of what the corporate alternative minimum tax was funding were a lot of those energy incentives that were part of the Inflation Reduction Act,” Strong noted.

The CAMT rules for a 15% minimum tax aren’t the same as the ones from the Organization for Economic Cooperation and Development, which haven’t been ratified in the U.S., despite the backing of the Biden administration. “Different rules, different tax,” said Strong. “They may operate in a simpler manner, but they are certainly different taxes that would apply.”

Corporate taxpayers will also need to be aware of a safe harbor that the Treasury and the IRS provided in Notice 2023-7 prior to releasing the draft rules.

“One of the things in an earlier notice that the government provided for was called a safe harbor method for determining if you’re an applicable corporation and subject to these rules or not,” said Strong. “It didn’t necessarily mean that you wouldn’t have to pay the tax if you went through this safe harbor. But generally what it did is it simplified the process of saying if these rules would apply.”

The safe harbor reduces the $1 billion in adjusted financial statement income down to $500 million for wholly domestic entities, and $50 million for foreign-parented multinational entities. But that doesn’t mean they’re off the hook completely.

“If I’m above those thresholds, even though I might not be subject to the tax itself, I still have a filing requirement,” said Strong. 

Companies will still have to go through the process of completing the forms to effectively show the IRS that they’re not subject to the tax.

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Continuous Auditing Transforms Corporate ERPs

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continuous auditing transforms corporate erps

As corporate accounting departments cross the threshold into late July 2026, the adoption of continuous, automated auditing systems has reached a definitive turning point. Driven by advances in artificial intelligence and deep integration with modern Enterprise Resource Planning (ERP) platforms, leading finance organizations are moving away from traditional, periodic post-hoc audits in favor of real-time, 100% transactional verification. This technological transition is redefining internal control environments, reducing compliance costs, and eliminating the structural delays inherent in legacy quarterly closing processes.

Unlike traditional auditing frameworks that rely on statistical sampling—a process that inevitably leaves operational blind spots—continuous auditing software monitors operational data feeds continuously. Every purchase order, electronic invoice, payroll disbursement, and cross-border wire transfer is automatically cross-referenced against established corporate governance parameters, regulatory tax schedules, and anti-fraud algorithms in real time. Anomalies or unauthorized ledger entries are flagged instantly, allowing internal audit teams to investigate and remediate compliance gaps immediately rather than months after the close of a financial period.

The implications for executive financial management are far-reaching. By embedding continuous verification directly into daily transaction workflows, chief financial officers gain uninterrupted visibility into the organization’s true financial standing. Real-time balance sheet auditing eliminates the severe operational bottlenecks associated with month-end and quarter-end financial reconciliations, freeing accounting professionals to focus on strategic financial modeling, tax planning, and capital allocation rather than manual data entry and spreadsheet consolidation.

However, implementing continuous auditing requires accounting leadership to invest heavily in data governance and technical upskilling. Internal audit teams must evolve from manual ledger reviewers into system architects capable of auditing complex algorithms and validating automated data pipelines. Accounting firms and corporate controllers that master continuous auditing will establish a resilient compliance framework capable of meeting stringent international regulatory standards with total transparency.

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

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U.S. Imposes New 50% Tariffs on Canadian Imports Under Rare Legal Provision

WASHINGTON — In a major escalation of cross-border trade friction, U.S. President Donald Trump has signed executive orders imposing new 50% tariffs on a wide selection of Canadian exports, citing discriminatory practices by Ottawa targeting American auto, dairy, and beverage industries.

The new duties, announced Monday, will take effect in 30 days. They target a broad spectrum of consumer and industrial goods—ranging from wine, liquor, and milk products to commercial cement, furniture, clothing, and hockey equipment.

Untested Legal Mechanism

To enact the sweeping measures, the administration invoked Section 338 of the Tariff Act of 1930—a rarely used legal provision allowing the executive branch to levy additional tariffs of up to 50% on foreign nations deemed to discriminate against U.S. commerce.

White House officials noted that Section 338 addresses trade discrimination rather than national security or economic emergencies. The move comes months after prior global emergency tariffs faced legal challenges in domestic courts, signaling Washington’s pivot toward alternate statutory authorities to maintain import duties.

Senior administration officials briefed reporters that the measure directly responds to Canadian provincial bans on U.S. alcohol, restrictions on American vehicle exports, and import quota disparities affecting U.S. dairy and cheese producers relative to third-party trading partners.

“While the administration continues to secure reciprocal trade agreements globally, Canada retaliated against efforts to protect domestic industry,” U.S. Trade Representative Jamieson Greer stated.

USMCA Impact and Carve-Outs

Significantly, the newly ordered 50% duties will apply to designated items even if they otherwise comply with the United States-Mexico-Canada Agreement (USMCA).

However, the administration confirmed key targeted exemptions:

  • Energy products (including oil and natural gas)
  • Potash and critical minerals
  • Fish and seafood
  • Goods already governed by sector-specific duties (such as existing steel and aluminum tariffs)

Administration representatives emphasized that the tariffs do not stem from recent disputes concerning drifting Canadian wildfire smoke, noting that policy options regarding environmental spillover remain under separate review.

Canadian Response and Market Reaction

Following the White House announcement, the Canadian dollar experienced a sharp decline against the U.S. dollar, falling approximately 0.4% during evening trading.

Canadian Prime Minister Mark Carney issued a statement emphasizing that Canada’s earlier counter-duties had merely matched previous U.S. trade actions. “Canada stands ready to engage intensively to address outstanding issues with the U.S. to the mutual benefit of our citizens,” Carney stated, pointing to detailed proposals Ottawa submitted to modernize the USMCA framework.

Ontario Premier Doug Ford took a firmer stance, urging a “dollar-for-dollar” reciprocal response if the measures go into effect on August 19.

With a 30-day implementation window before the duties officially lock in, industry associations and trade groups on both sides of the border are calling for urgent bilateral negotiations to avert further supply chain disruption across North America.

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Accounting

Automated Continuous Auditing: Transforming Compliance and Real-Time Financial Oversight

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Transforming Compliance and Real-Time Financial Oversight

The traditional accounting paradigm—defined by periodic monthly closures and post-hoc annual audits—is rapidly giving way to continuous, automated financial oversight. As of July 2026, forward-thinking accounting practices and multinational corporate finance departments are leveraging continuous auditing systems powered by advanced machine learning models. These systems monitor operational transactions in real time, shifting audit methodologies from sample-based post-analysis to absolute, 100% transaction-level verification.

The operational advantages of continuous auditing are transformative. Standard auditing procedures historically relied on statistical sampling, which, despite rigorous methodology, inherently left gaps where anomalies or fraudulent transactions could go undetected for months. Modern continuous auditing platforms integrate directly with enterprise resource planning (ERP) databases, instantly cross-referencing purchase orders, invoices, bank feeds, and tax records. Any deviation from established control parameters or unusual transaction behavior triggers immediate flags for internal audit teams, dramatically reducing detection lag from quarters to seconds.

Beyond fraud prevention, continuous auditing fundamentally alters internal reporting and decision-making. Executive leadership no longer has to wait weeks after the close of a quarter to evaluate precise financial standing; real-time verified ledger data provides an uninterrupted view of operating margins, tax liabilities, and cash flow dynamics. This real-time visibility enables corporate controllers to adjust capital allocation strategies dynamically, mitigating liquidity constraints and capitalizing on emerging commercial opportunities far more efficiently than competitors bound to legacy reporting cycles.

However, implementing continuous auditing requires accounting professionals to acquire new analytical capabilities. The role of the auditor is evolving from manual data reconciliation toward system validation, algorithmic model governance, and strategic risk interpretation. Accounting firms and corporate finance departments must invest in continuous technical education, ensuring that audit staff possess the data engineering skills necessary to design, maintain, and evaluate complex automated compliance systems.

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