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What not-for-profits and their accountants need to know about the OBBBA

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The One Big Beautiful Bill Act, signed into law on July 4, contains several provisions that could affect the future of not-for-profit organizations. 

One provision creates a permanent cash contribution deduction for non-itemizers. This deduction is limited to $1,000 for single filers ($2,000 for those married filing jointly) and notably, this deduction does not apply to contributions made to supporting organizations under Section 509(a)(3) of the Tax Code and to donor-advised funds. 

Additionally, a limitation on charitable contributions for taxpayers who itemize deductions was created by imposing a floor equal to 0.5% of the taxpayer’s contribution base for that taxable year. 

These provisions will likely increase contributions from individuals who do not itemize, as non-itemizers are not subject to the 0.5% limitation on their contributions.

Taxpayers who itemize deductions will feel the impact of this provision the most. For example, a married couple with an adjusted gross income of $500,000 will have their charitable contributions reduced by $2,500 because of it. The remaining amount of charitable contributions may not provide a tax benefit to the couple if they need to use a portion of the remaining charitable contributions to exceed the standard deduction limit for married filing jointly taxpayers. Effectively, those contributions have no tax benefit to the MFJ couple. This can further restrict an individual’s tax benefit of charitable contributions. 

Not-for-profit organizations need to be aware of this impact on their individual contribution base. In this situation, taxpayers who want to maximize the tax benefit of their charitable contributions may want to set up a donor-advised fund to “stack contributions.” The taxpayer could fund the DAF in one year with contributions they would have made over several years and then make distributions from the DAF on an annual basis. By doing this, the contributions would only be subject to the 0.5% limitation once, providing more overall tax benefit for the same charitable contributions. Not-for-profit organizations should ask contributors if they have a DAF or be ready to refer them to an organization that can assist them in establishing one.

Excise tax modification

Under previous law, certain private colleges and universities had to pay a 1.4% excise tax on their net investment income if they had at least 500 tuition-paying students and a student-adjusted endowment of $500,000 or more. The OBBBA enacted two major changes effective for tax years beginning after Dec. 31, 2025. The student threshold increased from 500 to 3,000 tuition-paying students, likely resulting in fewer institutions subject to the excise tax. Additionally, a tiered tax system will replace the flat 1.4% with different rates based on the institution’s student adjusted endowment as follows:

Student adjusted endowment Excise tax rate
$500,000–$749,999 1.4%
$750,000–$1,999,999 4%
$2,000,000+ 8%

This tiered excise tax model intentionally targets private colleges and universities with large endowments. This provision was originally enacted to encourage private colleges and universities with larger endowments to use the funds to reduce the cost of education or provide more scholarships to students. It demonstrates that Congress continues to examine the amounts held by not-for-profit organizations in their endowment funds and has identified it as a potential revenue raiser for future legislation. Not-for-profit organizations should continue to work with peer advocacy groups to coordinate responses to any future expansion of this excise tax.

Tax credit for individual scholarship contributions

Effective for tax years beginning after Dec. 31, 2026, a new tax credit of up to $1,700 has been created specifically for individuals who make charitable contributions to public charities that provide scholarships to qualifying elementary and secondary school students. To qualify for the scholarships, students must come from homes with incomes below 300% of the area’s median gross income and be eligible to enroll in a public elementary or secondary school. 

The credit provides more benefit than a charitable contribution deduction as it is a direct offset to the individual’s tax liability and is also not subject to the deduction limitations on either itemizers or non-itemizers. Individuals who are looking to maximize the tax benefit of their charitable contributions and existing qualifying organizations will benefit the most from this change.

1% floor on corporate charitable contribution deductions

This provision establishes a floor equal to 1% of taxable income for the deductibility of corporate charitable contributions. Exceeding 1% is deductible up to 10% and if a corporation’s contributions exceed the 10% limit, the provision allows taxpayers to add the amount disallowed under the 1% floor to the amount carried over to the following year.

While this change is unlikely to significantly impact charitable giving by large corporations, it may cause small or midsized corporations to consider reducing contributions to charities and instead look to sponsoring community events. These business expenses would not be subject to the 1% floor and still enable the corporations to support their local community. 

Nonprofit organizations that rely heavily on direct charitable contributions from corporate donors should anticipate a change in how small and midsized companies approach charitable support. The not-for-profit’s fundraising development team should continue to focus on the social impact of the contribution when addressing corporate donors and look for ways to increase direct sponsorship of community activities to help corporate donors maximize the after-tax benefit of the contribution.

No tax on overtime

The OBBBA introduced a maximum deduction for qualified overtime income of $12,500 for single filers ($25,000 for joint returns). Not-for-profit organizations are now required to separately state the amount of qualified overtime on their employees’ Form W-2. 

This additional filing requirement may cause increased administrative time or changes to the payroll reporting process. On the other hand, we may see employees express increased interest in working overtime hours.

Excess compensation

Before the OBBBA, only the top five highest-paid employees at a tax-exempt organization were subject to the excise tax on compensation in excess of $1 million. With the new provision, this rule has expanded to include any employee or former employee that has earned over $1 million during any tax year after Dec. 31, 2016. This results in more highly paid employees being subject to the excise tax.

This change is likely to impact many large not-for-profit organizations that have more than five employees with excess compensation. These organizations should further refine their internal processes to ensure they identify individuals meeting this requirement, especially those individuals compensated by related parties.

It is important to note that the exception to this rule for remuneration for medical services remains in effect.

What now?

These OBBBA provisions will require some learning and flexibility from not-for-profit organizations. While there are challenges that come with these changes, there are also new opportunities and incentives for those looking to make charitable contributions.

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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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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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