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IRS set to open annual CAP program for big companies

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The Internal Revenue Service is preparing to open the 2026 Compliance Assurance Process program application period for public companies with at least $10 million in assets.

The annual CAP program is scheduled to run this year from Sept. 3 to Oct. 31, 2025, and it comes at a time when the Trump administration and Republicans in Congress recently passed the One Big Beautiful Bill Act, which extends and expands tax breaks for large corporations.

If they’re accepted into the program, the IRS said it will inform applicants in February 2026.

CAP originated 20 years ago, back in 2005, and boasts real-time issue resolution through cooperative interaction between large corporate taxpayers and the IRS to improve federal tax compliance by resolving potential issues before a tax return is filed.

To be eligible to apply for CAP, applicants need to meet the following requirements:

  • Have assets of $10 million or more;
  • Be a U.S. publicly traded corporation with a legal requirement to prepare and submit SEC Forms 10-K (annual report), 10-Q (quarterly report) and 8-K (current report) or a privately held C-corporation, including foreign-owned. Privately held applicants will be required to submit audited financial statements prepared in accordance with U.S. Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards (IFRS) or another permissible method, as deemed appropriate by the IRS, specific to the taxpayer applying to the CAP program on an annual basis and unaudited financial quarterly statements. The audited financial statements must contain an unqualified audit opinion from an independent auditor. Additionally, the net income or loss per the audited financial statements must reconcile to the Schedule M-3 Line 4(a), worldwide consolidated net income (loss);
  • Not be under investigation by, or in litigation with, any government agency that would limit IRS access to current tax records.

For the 2026 CAP cycle, the IRS is continuing the open year eligibility criteria of allowing only one open filed return and one open unfiled return on the first day of the CAP applicant’s tax year. There are several exceptions to this requirement, however, such as pending Advance Pricing Agreement resolution or Competent Authority Assistance, two other programs for large corporate taxpayers.

The IRS also pointed to several other highlights and updates on the CAP program for 2026, including updates on audited financial statement requirements. General program information and the 2026 application details are available on the CAP webpage.   

The Inflation Reduction Act and the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act added several new provisions to the Tax Code for large corporate taxpayers, including the Corporate Alternative Minimum Tax, the excise tax on stock buybacks, and several clean energy credits, which will require a review for impacted taxpayers. Sine these reviews may initially extend beyond the CAP timelines, the IRS has added an exception to the closed/open year eligibility requirement, such that a tax year that remains open only because of an outstanding IRA and/or CHIPS Act tax issue will not be counted as an open filed return on the first day of the applicant’s CAP year for purposes of the CAP Eligibility return criterion.

For a new applicant currently under examination to be eligible for participation in the program, the applicant can have no more than three tax years open for examination on the first day of the CAP applicant’s tax year. The IRS examination team would determine if it is feasible these open years could close from the examination group no later than 12 months after the first day of the CAP applicant’s tax year for continued eligibility (and the accepted applicant would then concur by signing the CAP MOU).

For the 2026 CAP cycle, the IRS is continuing to use the expanded criteria announced last year. In addition to considering publicly held C corporations, the IRS said it would accept applications from privately held C corporations, including foreign owned. Privately held applicants will be required to submit audited financial statements prepared in accordance with U.S. GAAP, International Financial Reporting Standards or another permissible method, as deemed appropriate by the IRS. The audited financial statements need to be specific to the taxpayer applying to the CAP program. As such, related entity and/or parent audited financial statements will not be allowed. The audited financial statements have to contain an unqualified audit opinion from an independent auditor. In addition, the net income or loss per the audited financial statements must reconcile to the Schedule M-3 Line 4(a), worldwide consolidated net income (loss).

Also for large corporate taxpayers, the IRS announced last month that it’s proposing to streamline the examination process to reduce the time spent on cases.

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Accounting

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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Accounting

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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