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Tax Strategy: The IRS and the new Trump administration

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It is not surprising that a new Republican administration in the White House would create issues for the Internal Revenue Service. Past Republican administrations tended to starve the IRS for funds, resulting in a decline in audit activity and customer service. 

The new administration will have a new Treasury secretary and a new IRS commissioner. New executive orders have already had an impact on the IRS. The last Trump administration placed limits on new federal regulations, and the IRS has been active since the November election in promulgating new regulations. The new Treasury Secretary, Scott Bessent, has indicated that his top priority is extension of the expiring provisions of the Tax Cuts and Jobs Act, many of which expire at the end of 2025.

Executive orders

One executive order of the new administration has placed a freeze on almost all federal hiring. For most federal departments, the freeze only lasts long enough for the departments to prepare plans justifying additional hiring. For the IRS, however, not only the Treasury secretary but also Musk’s Department of Government Efficiency are required to approve any resumption in IRS hiring. The agency has been forced to revoke hiring offers to new graduates and others. Legislation has already reduced the $80 billion in funding the IRS received under the Inflation Reduction Act by $40 billion. 

An executive order also directed withdrawal of any U.S. support for the Organization of Economic Development’s Pillar One and Pillar Two initiatives on international taxation to address base erosion and profit-shifting and a minimum corporate tax. The primary concern of the administration is that countries might be able to tax a multinational corporation doing business in the country if it was not paying at least a minimum corporate tax.

The executive order on Schedule F reclassification of federal workers, if upheld in the courts, could expose more IRS employees to termination by removing their protected status as Civil Service employees.

Scott Bessent, founder and CEO of Key Square Group LP and Treasury Secretary nominee, during a Senate Finance Committee confirmation hearing
Scott Bessent during a Senate Finance Committee confirmation hearing

Kent Nishimura/Bloomberg

The Tax Cuts and Jobs Act

Republicans in Congress are still working on how to approach extension of the expiring provisions of the Tax Cuts and Jobs Act. The House is focused on one budget reconciliation bill that would address both border and tax issues, while the Senate would prefer two reconciliation bills, with the tax bill coming later in the year. 

There is also some debate about whether extending existing provisions of the Tax Code requires revenue offsets in the legislation. Some Republicans are concerned about adding too much to the federal deficit, and the Republicans need to hold almost all Republican votes together to pass a budget reconciliation bill with a simple majority in both chambers of Congress. The narrow majorities might also force Congress to raise the $10,000 limit on the state and local tax deduction to gain the support of Republicans from New York and other high tax states. 

There are also a few business provisions in the Tax Cuts and Jobs Act that started phasing down a few years ago: the expensing of bonus depreciation, the limitation on the business interest deduction, and the research and experimentation expense deduction. Efforts to renew those through last year had proposed retroactivity back to the start of the phase-downs. If those are still retroactive in the tax legislation this year, the changes could retroactively impact 2024 tax returns as well as earlier returns.

IRS regulations

As is common at the end of the year, the IRS released a lot of regulations at the end of the 2024, but also in January before President Trump was sworn in. The first Trump administration had placed restrictions on issuing new federal regulations. Some of the regulatory effort may have been a guard against further regulatory restrictions. IRS regulations are somewhat usual in that regard since taxpayers are often hoping for the issuance of new regulations to provide guidance on ambiguous provisions of tax law, while many other federal regulations may be viewed as a burden to business.

Many of the recently promulgated regulations relate to the clean energy provisions of the Inflation Reduction Act. At the end of 2024 and beginning of 2025, final regulations were issued on:

  • The definition of “energy project” for purposes of the Energy Investment Credit; 
  • The Clean Hydrogen Production Credit and Energy Property Election; 
  • The Clean Electricity Production and Clean Electricity Investment Credits; and,
  • The allocation of the low-income community bonus credit for the Code Sec. 48E Clean Energy Investment Credit.

Plus, proposed regulations were issued on the emission rules for the Code Sec. 45Z Clean Fuel Production Credit, and on the Code Sec. 45W Commercial Clean Vehicle Credit. 
The authorization in the Inflation Reduction Act of a study on direct filing of tax returns with the IRS has resulted for 2024 in a Direct File trial program involving 25 states. Republicans seem generally opposed to the Direct File program, although Secretary Bessent has said that it is safe at least for the current filing season.

President Trump has discussed eliminating many of these clean energy credits, especially those related to electric vehicles, although Republicans in some states that benefit from certain of the credits may push for their survival.

Recent regulations in the crypto area include final regulations on digital asset reporting by front-end brokers and final and proposed regulations on digital content and closed transactions. President Trump has also expressed support for the crypto industry, although it is not clear how he views these reporting requirements.

Other recent regulations include:

  • Proposed regulations on the Previously Taxed Earnings Credit and basis adjustments; 
  • Final regulations on retirement of tax-exempt bonds; 
  • Final regulations on supervisory approval of penalties; 
  • Final regulations on partnership basis-shifting transactions as reportable transactions; 
  • Final regulations on certain disregarded payments and dual consolidated losses; 
  • Final regulations on the resolution of federal tax controversies;
  • Proposed regulations implementing catch-up contribution changes; 
  • Proposed regulations on the executive compensation deduction limit; 
  • Proposed regulations on corporate separation, incorporation and reorganization matters; and,
  • Final regulations on micro-captive transactions and transactions of interest.

Other issues

Congressional legislation has authorized the expansion of Form 1099-K reporting by third-party payment providers of transactions more than $600. The IRS has been delaying implementation of this requirement, and, for 2024, is only requiring reporting of transactions involving more than $5,000 ($2,500 in 2025 and $600 in 2026). Some Republicans have proposed restoring the old $20,000-and-200-transactions limit, or at least keeping it from falling to $600.

President Trump has suggested setting up a separate External Revenue Service to deal with tariff issues.

Summary

The generous funding that the IRS has enjoyed for the last few years seems likely to be coming to an end, perhaps along with improvements in customer service, audits and collections, and system upgrades. 

The current tax filing season should be relatively normal; however, the future beyond that is hard to predict. It is likely that significant tax legislation will pass this year; however, with the thin Republican majorities and deficit concerns, the scope of that legislation and possible revenue raisers are also hard to predict. Tariffs may not count as revenue raisers; however, their presence may make some Republicans more comfortable with adding to the deficit in extending Tax Cuts and Jobs Act provisions.

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Accounting

Art of Accounting: The most important issue facing the profession

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Complimentary Access Pill

Enjoy complimentary access to top ideas and insights — selected by our editors.

The most important issue is staff recruitment, training, retention and work conditions. While each of these is a separate issue, the whole staff issue is a neglected area when it should be the top area of concern. This has been so since I started practicing, and I am perplexed that meaningful actions are not taken to remedy the situation. I did, and many firms do, and they are much more successful than the others, but too many do not deal realistically with this.

Recruitment: Starting salaries have not kept up with overall business conditions, and I do not believe they have remained competitive when about 15 years ago they were at the top of the curve. This can be easily corrected by firms increasing their starting salaries. Many refer to the added 30 credits as a hindrance, but I don’t believe this is a more important objection than the lower starting salaries being offered. Staff recognize having master’s degrees as an enhancement that makes themselves more valuable and they feel good about it … after they get their degree.

Training: Training is a significant area and is done by many firms, particularly smaller practices, as a cookie cutter obligatory process, not focused on the staff person’s responsibilities and expected work assignments. Firms send staff to available CPE courses when they should be developing customized CPE, either in their firm or in partnership with similar firms or through their state society committees. (I’ve done all of these and it works.) Firms also need to become training organizations using error disclosure as immediate training opportunities and deliberate on-the-job training by everyone in a supervisory position. Firms’ cultures have to be to train and develop. In conjunction with this, all supervisors need to be trained on how to train.

Retention: Turnover is terrible. Two years ago, a Big Four firm had 25% staff turnover. Last year it was 17% (and they were voted one of the Top 100 best places to work both years! Huh?). Many firms neglect “marketing” the benefits of working for them and take the current staff for granted. Retention needs a deliberate effort by every supervisor, manager, partner and owner. It needs work and will pay the best dividends. This effort might not stop a person from leaving, but it could retain them for an extra year or more. An attitude that you want them to stay forever also helps.

Work conditions: Tax season hours are untenable at most firms, while some larger firms maintain tax season conditions after tax season ends or add mini periods of extended hours. In my own informal and unofficial exit polls, most people provide as the primary reason for leaving a lack of work-life balance. I know people from top 10 firms that leave public accounting for reasons that indicate a complete noncompliance by their employers with the stated “favorable work-life and caring atmosphere and culture” in those firms’ recruitment brochures. Firms show a total lack of attention to this.  

Solution: This is an industry problem, but it can only be solved one firm at a time. My solution is to acknowledge the problem at your practice and then make every change necessary to eliminate that problem. You might not be able to do it immediately, but you can start immediately and work on these issues as they come up while starting a serious and meaningful training program. Every change needed can be implemented within a year. Let that year start now!

Do not hesitate to contact me at [email protected] with your practice management questions or about engagements you might not be able to perform. 

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Accounting

KPMG rolls out tool to model tariff impacts

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Big Four firm KPMG announced the release of its new Tariff Modeler tool, made to help users prepare for and respond to ongoing trade policy changes. 

The solution draws on client-specific historical data, current tariff information, and the user’s organizational objectives to generate a tailored interactive dashboard that can provide detailed financial information with trade-related insights and data visualizations. People can examine their trade data, identify areas of risk, and understand the financial impacts of said risks. The solution also does in-depth scenario modeling, letting users look at a number of different hypotheticals and examine how tariff policy impacts them. Users can also refine insights by isolating high risk areas based on product, vendor, and country of origin. 

Users get access to comprehensive tariff analysis that provides detailed insights into current and potential tariffs affecting your products and markets; real-time updates on the latest tariff changes and regulations; customizable reports to help make informed decisions and communicate effectively with key stakeholders; and an intuitive interface made to be understandable to those who are not trade experts. 

“Today’s volatile global trade landscape requires companies to fundamentally rethink how they anticipate and respond to policy shifts,” says Rema Serafi, KPMG’s vice chair of tax. “By leveraging AI to transform vast streams of global trade data into actionable intelligence, organizations can rapidly model complex scenarios and make more informed decisions. Those who embrace this AI-powered approach will not only navigate current uncertainties but also position themselves to capitalize on emerging opportunities in this new normal of trade complexity.”

Llamadex Investment

KPMG also last week announced a minority investment in a company, LlamaIndex, that makes data infrastructure for large language models. 

LlamaIndex’s suite of services enables organizations to connect their proprietary data to large language models (LLMs). The company’s flagship offerings include LlamaParse, which provides parsing for complex documents with embedded tables and figures, and LlamaCloud, a managed ingestion and retrieval service for Retrieval Augmented Generation implementations.

KPMG’s investment is spearheaded by KPMG Ventures, which is dedicated to collaborating with and investing in early-stage start-ups in areas like agentic AI, data infrastructure, cybersecurity, and more. KPMG Venture’s minority equity investment follows recent investments in other AI-driven startups including Ema, Wokelo and Rhino.AI.  

“As we continue to innovate and push boundaries in applied AI, a robust data foundation is essential for building effective AI systems, particularly sophisticated knowledge assistants and agentic solutions,” said Swami Chandrasekaran, KPMG principal for AI and data labs. “LlamaCloud and LlamaIndex provide the frameworks necessary to access, curate, and ingest data at-scale, enabling KPMG to develop differentiated, industry-specific solutions that deliver measurable business outcomes for our clients.”

KPMG’s investment was made in parallel to another made by the data and AI company Databricks. Together, these investments will accelerate the development and adoption of LlamaIndex’s innovative LlamaCloud and LlamaParse services, which have emerged as critical tools for enterprises implementing production-grade AI solutions.

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Accounting

Beyond rainmakers: The new face of business development in accounting

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The rainmaker days are over.

Rainmakers, the select charismatic few — usually partners — who brought in the vast majority of an accounting firm’s clients, are becoming obsolete as firms professionalize business development and shift their reliance off the individual and onto the collective team. Looking ahead, experts say the most successful firms will be those that entrench themselves in a niche and poach clients with their hyperspecialized services.

In the past, firms’ growth strategies were rudimentary and unsophisticated, according to Gale Crosley, CEO of Crosley and Co. Firms relied on the individual contributions of rainmakers to generate the bulk of their revenue while growth strategies remained largely unchanged year to year. Now, especially since the Paycheck Protection Program stimulated growth during the COVID-19 pandemic, “driving demand is on cruise control,” Crosley said.

“The fish are jumping in the boat. They’ve been jumping in the boat for five years, and it’s not a business problem they have to solve right now,” she explained.

Modern rainmaking art.jpg

It’s a straightforward scenario where there is too much work to do and not enough talent or time to do it, meaning strategic growth is on the backburner for many firms as they manage day-to-day business operations.

“Fulfilling the demand side is sucking all the energy out of the firm,” Crosley said. “They’re totally focused on getting the laundry out the door, offshoring and technology.”

“The firms who are on it — the A+ firms who have always been on it — they’re not hitting the pause button,” she continued. “Only firms who always knew that they had to carve out that time and say, ‘We’ve got to look at growth strategies for the future,’ those are the ones who are doing it right.”

Modernizing business development

Firms are now formalizing and structuring the process of finding and bringing in new clients. The first key to modernizing business development is moving the responsibility of client acquisition beyond individual rainmakers.

“It’s taking more of a matrix, relationship-focused approach, instead of a singular source of that rainmaker being out with the client,” said Rebekah Gardner, chief growth officer at Top 25 Firm Wipfli. “You start to identify these segments, these clients and prospects, and then you look at the team that you have on your bench, and you start to match up relationships and skills, and you build that matrix.”

The second key is specialization. Competition for clients is increasing as more firms look to own entire market segments and tailor their services to those select niches. Firms that choose to stay generalists put themselves at risk of losing business.

(Read more:Pathways to Growth: Strategic client development.)

“You have got to have industry experts sitting on your team so that you build that ability to have a conversation at their level,” Gardner said. “If you can’t show up like that, I don’t think you belong in the game sometimes.”

“Specialization and niches allow firms to perform a much higher value service to their clients,” said Tim Petrey, CEO of HD Growth Partners, a member firm of private-equity-backed accounting firm platform Ascend. “They can get much deeper with a client than the surface-level tax and compliance work. As a result, you form a higher degree of trust between the accountant that owns the relationship and the client much faster. It can be difficult for a ‘generalist’ style firm to compete with industry experts.”

But it’s easier said than done. Becoming a specialist requires the difficult task of dropping low-profit, time-consuming clients, and focusing resources on high-growth, high-return clients.

“Firms need to improve by looking closely at the clients they best serve and build a marketing strategy around that,” Petrey added. “Treat your firm like a real business and it’s amazing what comes naturally from that. Treating a firm like a partnership often leaves marketing efforts stale because partners can’t agree on the strategy, the ideal client profile, the budget, or even just as simply the contribution of their staff’s time to the efforts.”

The decline of rainmakers

The accounting profession’s ongoing labor shortage impacts everything within a firm, especially business development.

“Finding great accountants is hard enough. Finding great accountants who can sell is like hunting for a unicorn,” Petrey said.

“With one person coming into an industry for every five who are leaving, staff are getting asked to do things earlier on in their careers than their predecessors. Partners and shareholders are getting younger and younger because firms need to find a way to get those great people locked in for years,” Petrey continued. “As a result, most firms never focused on building any real brand loyalty. There is loyalty to an individual but not loyalty to a brand. The rainmakers of the prior generation are still out winning business the old school way, but there aren’t enough of those rainmakers in the next generation.”

“That’s the crux of the problem,” said Bob Lewis, president of The Visionary Group. “Why we have so much M&A going on right now is because of the lack of business development and a lack of networking skills. “

Besides, the traditional rainmaker model isn’t necessarily the best fit for modern firm culture. “When a firm has a great rainmaker that is a poor manager, leader or colleague, they’ll often look past their issues as a leader because they generate so much revenue, which causes firms to further struggle to maintain or improve culture,” Petrey said.

Instead of relying on rainmakers, some firms have turned to the internet and search-engine optimization to supplement client acquisition.

“What they missed is that the activity you generate through SEO is typically the type of clients you don’t want. It’s clients that are searching the internet looking for a new provider,” Lewis said. “The good clients go through the professional network. They go through the bankers, they go through their lawyers, they go through the insurance agencies, and they get referrals into another accounting firm.”

“I can replace the accounting part, the tax part, overnight. I can’t replace the trust part, and that’s what people have learned and figured out how to sell,” Lewis said.

The rise of the CGO

With the sunset of the rainmaker era comes the dawn of the chief growth officer.

CGOs are the newest additions to small and midsized firms’ staff. While mergers and acquisitions certainly fall within a CGO’s remit, they are also focused on trimming clients that don’t fit the firm’s portfolio, upskilling the next generation of partners, adding more advisory services, and expanding relationships with existing clients, Lewis said.

CGOs also need to be “making sure that people inside of the firm are being deployed in their highest and best use,” Wipfli’s Gardner said. “Traditionally we’ve used our own partners, rank and file, to think about these things, but sometimes it takes an outsider perspective to come in and say, ‘Hey, let’s think about this a little bit differently.”

Unlike the average accountant, CGOs specialize in general management. The addition of them into accounting firms is a new trend that has only been accelerated by the wave of private equity investment in the profession.

(Read more: The rise of the chief growth officer.“)

“Most accounting firms have historically run like a partnership rather than a real business,” Petrey said. “PE will continue to professionalize firms of all sizes to be better and smarter at business development. As a result, non-PE backed firms will need to find ways to make that investment into their firms to remain competitive.”

“​​The preexisting resource constraints and the seasonal nature of the business makes it really hard for anyone to make meaningful progress on a strategic initiative,” said David Wurtzbacher, CEO of Ascend, which is backed by PE firm Alpine Investors. Each of Ascend’s platform firms is required to have a CGO.

“For a long time, the public accounting industry couldn’t and didn’t attract general management type talent — think MBAs — because of the partnership model. It was, ‘We can’t really pay you that much, and we definitely can’t give you equity in these companies, and we’re not really growing that much,’ and so you didn’t have access to the talent markets the way other industries have access to it.”

“But the fact remains, there are people outside the industry who might be better suited for driving growth and transformation and strategic initiatives,” Wurtzbacher said.

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