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Leverage depreciation planning to mitigate tax legislation uncertainty

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CPAs and their clients have been dealing with uncertainty surrounding Section 174 legislation for the last few years. Under the Tax Cuts and Jobs Act of 2017, research expenditures under Section 174 were required to be amortized over five years starting in 2022. This ruling negatively impacted taxpayers in manufacturing, engineering and other industries. Due to the punitive nature of this provision, few tax experts or legislators ever expected this to come to reality. Unfortunately, as of today, the federal government has not been able to fix this provision.

On January 31, Congress took the first step to fix this situation by passing H.R. 7024, the Tax Relief for American Families and Workers Act of 2024. This bill would restore 174 expensing for U.S.-based research and development, reset the 163(j)-limitation index to EBITDA, and extend 100% bonus depreciation. Under this legislation, these provisions would be extended through the end of 2025, providing significant relief to businesses nationwide. Unfortunately, this bill has stalled in the Senate even with bipartisan support.

Now that tax season has closed, the uncertainty of legislation creates a dilemma for CPAs. Should they have finished tax returns when they don’t have all the answers? And how should they continue to communicate this issue to clients? The short answer for most tax preparation companies is that they must move forward based on the law as it currently exists. This means completing tax returns, estimates and extensions as if the Tax Relief for American Families and Workers Act will not pass. This allows CPAs to complete returns, or for clients that desire to go on extension, file correct estimated payments.

Many will ask what happens if this bill passes after a return is filed. This can be a big deal for taxpayers. Although not all taxpayers are subject to 174, almost every business is impacted by the changes to bonus depreciation. If this passes, taxpayers will have the opportunity to either amend or supersede a return, or file a 3115, presenting a tax planning opportunity for CPAs to determine the best year for taxpayers to take advantage of the changes.

In the meantime, 174 amortization requirements are becoming a major issue for many companies as they are causing a significant tax burden that companies may not be able to handle. This is further amplified by high interest rates, which can result in higher interest rates on bank loans. One possible solution is to consider changes in depreciation to make up for the shortfall. Real estate owners may be able to use a cost segregation study to create deductions that can offset the 174 tax increase.

Let’s consider a manufacturing company that spends $2 million annually on 174 expenditures. The change requiring 174 amortization in 2022 meant that instead of deducting $2 million, they were limited to $200,000, creating an additional $1.8 million in taxable income. This unexpected increase in taxable income would have put a considerable burden on the company. Assuming a 30% tax rate, they would have been required to pay an additional $540,000 in taxes for 2022.

To address this the company reviewed their assets. In 2018, the company purchased a building for $18 million. They completed a cost segregation study that found approximately 20% of the $18 million could be moved to shorter lives. This resulted in around $3.6 million of bonus-eligible assets, which allowed them to file a change in accounting method with a “catch-up adjustment” of nearly $3.3 million. This adjustment more than offset the additional tax liability caused by the 174 amortization requirement.

This example demonstrates how examining cost segregation and other deductions can help mitigate the uncertainty companies face due to unpredictable tax bills. It’s important to note that this doesn’t imply that we should stop advocating for Washington to address these issues and pass H.R. 7024. However, in the meantime, there are opportunities taxpayers can consider to offset the financial burdens of 174 amortization requirements.

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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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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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