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    Tuesday, October 20, 2026

    Accounting & Tax Watch

    Accounting & Tax Watch: the standards and tax rules on the CFO agenda, each read for whether it protects or creates enterprise value.

    16 accounting pronouncements and 9 tax rules, reviewed . Daily coverage for finance leaders is on CFO Insights. For how the tax act, CAMT and the new software rules interact, read the controller's read.

    A planning reference, not accounting, tax or legal advice. Effective dates shown are for calendar-year public companies unless the row says otherwise; confirm applicability with your auditors and tax advisers.

    Coming due in the next 18 months

    1. Jan 2027 · ASU 2024-03 and ASU 2025-01 — Disaggregation of income statement expenses (DISE)
    2. Jan 2027 · ASU 2025-03 — Determining the accounting acquirer when a VIE is acquired
    3. Jan 2027 · ASU 2025-04 — Share-based consideration payable to a customer
    4. Jan 2027 · ASU 2025-09 — Hedge accounting improvements (ASC 815)
    5. Jan 2027 · ASU 2026-01 — Paid-in-kind dividends on equity-classified preferred stock (Topic 505)
    6. Jan 2027 · IFRS 18 — Presentation and Disclosure in Financial Statements (replaces IAS 1)
    7. Jan 2027 · IFRS 19 — Subsidiaries without Public Accountability: Disclosures
    8. Jan 2028 · ASU 2025-06 — Internal-use software (ASC 350-40) targeted improvements
    9. Jan 2028 · ASU 2025-11 — Interim reporting (ASC 270) narrow-scope improvements
    10. Jan 2028 · ASU 2026-02 — Environmental credits and environmental credit obligations (new Topic 818)
    11. Jan 2028 · ASU 2026-03 — Fair value of equity securities with contractual sale restrictions (investment companies)

    Accounting pronouncements

    FASB · ASU 2023-09

    Income tax disclosures (ASC 740)

    Protect valueIn forceEffective Jan 2025Evidence grade D
    What changes
    Public companies must disaggregate the rate reconciliation into prescribed categories and disclose income taxes paid by federal, state and foreign jurisdiction, with any jurisdiction at 5% or more of the total shown separately.
    Why it matters for enterprise value
    Investors can now see where cash taxes are actually paid and which items move the effective rate. A tax structure that looked efficient in a single rate line is now visible jurisdiction by jurisdiction.
    What to do now
    Reconcile the new disclosure to the tax provision and to the country-by-country report before analysts do the comparison themselves.
    Effective
    Public business entities: annual periods beginning after December 15, 2024 (first calendar-year 10-K: fiscal 2025). Other entities: one year later.

    FASB · ASU 2023-08

    Crypto assets at fair value

    Create valueIn forceEffective Jan 2025Evidence grade D
    What changes
    In-scope crypto assets are measured at fair value through net income and presented separately, replacing the cost-less-impairment model.
    Why it matters for enterprise value
    Treasury crypto holdings report economic value rather than only impairments, but they now add volatility to earnings.
    What to do now
    If the balance sheet holds or accepts digital assets, set the treasury policy and the earnings-volatility disclosure together.
    Effective
    Fiscal years beginning after December 15, 2024, including interim periods.

    FASB · ASU 2025-05

    Credit losses on current accounts receivable and contract assets

    Create valueIn forceEffective Jan 2026Evidence grade D
    What changes
    Adds a practical expedient to assume current conditions persist over the life of current receivables and contract assets when estimating expected credit losses, which simplifies the CECL calculation on trade receivables.
    Why it matters for enterprise value
    Less modeling effort on the largest working-capital asset, and a reserve that moves with what is actually happening in collections.
    What to do now
    Decide whether to elect the expedient and pair it with the collections forecast so the reserve and DSO tell the same story.
    Effective
    Annual periods beginning after December 15, 2025, including interim periods; early adoption permitted.

    IASB · Amendments to IFRS 9 and IFRS 7

    Classification and measurement of financial instruments

    Protect valueIn forceEffective Jan 2026Evidence grade D
    What changes
    Clarifies when a financial liability settled by electronic payment can be derecognized and how to assess contractual cash flows with ESG-linked or similar contingent features, with new disclosures.
    Why it matters for enterprise value
    Sustainability-linked loans and electronic payment cut-offs are common; the amendments settle measurement questions that drove inconsistency.
    What to do now
    Confirm treatment of sustainability-linked debt and month-end electronic payments under the amended guidance.
    Effective
    Annual periods beginning on or after January 1, 2026.

    FASB · ASU 2024-03 and ASU 2025-01

    Disaggregation of income statement expenses (DISE)

    Protect valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    Public companies must break relevant expense captions into purchases of inventory, employee compensation, depreciation, intangible amortization and other natural categories in the notes, and disclose selling expenses. ASU 2025-01 fixed the effective date.
    Why it matters for enterprise value
    The cost base becomes legible to investors by nature, not only by function. Margin stories built on reallocating costs between captions will be easier to check.
    What to do now
    Confirm the ERP and chart of accounts can tag expense by nature at caption level, and dry-run the 2027 disclosure on 2026 actuals.
    Effective
    Public business entities: annual periods beginning after December 15, 2026, and interim periods beginning after December 15, 2027.

    FASB · ASU 2025-03

    Determining the accounting acquirer when a VIE is acquired

    Protect valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    Requires the general business-combination factors to be used to identify the accounting acquirer when the legal acquiree is a variable interest entity that is a business, rather than defaulting to the primary beneficiary.
    Why it matters for enterprise value
    Which party is the acquirer decides whose assets are stepped up and how goodwill lands. Getting it wrong restates the deal.
    What to do now
    Add the VIE acquirer test to the M&A accounting checklist for any deal closing in 2027 or later.
    Effective
    Annual periods beginning after December 15, 2026, including interim periods; applied prospectively to acquisitions after adoption.

    FASB · ASU 2025-04

    Share-based consideration payable to a customer

    Protect valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    Clarifies how equity instruments granted to customers (for example warrants tied to purchase volumes) are measured and when they reduce revenue.
    Why it matters for enterprise value
    Commercial deals that pay customers in equity move reported revenue; the clarified guidance reduces judgment and restatement risk.
    What to do now
    Inventory customer warrant and equity arrangements and confirm the revenue reduction profile under the new guidance.
    Effective
    Annual periods beginning after December 15, 2026, including interim periods.

    FASB · ASU 2025-09

    Hedge accounting improvements (ASC 815)

    Create valueUpcomingEffective Jan 2027Evidence grade E
    What changes
    Targeted changes that make more economic hedging strategies qualify for hedge accounting, including hedges of forecasted transactions and groups of similar exposures.
    Why it matters for enterprise value
    Hedges that already reduce risk can stop producing earnings volatility that has nothing to do with the business.
    What to do now
    Ask treasury which current economic hedges fail hedge accounting today and whether they would qualify after adoption.
    Effective
    Public business entities: annual periods beginning after December 15, 2026. Other entities: one year later. Early adoption permitted from issuance (November 25, 2025).

    Still moving: Secondary sources disagree on the effective date (one firm lists fiscal years beginning after December 15, 2027). The split shown here reads that as a public versus private difference; confirm against the ASU text.

    FASB · ASU 2026-01

    Paid-in-kind dividends on equity-classified preferred stock (Topic 505)

    Protect valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    Specifies how PIK dividends on equity-classified preferred stock are initially measured. Liability-classified preferred stock under ASC 480 is out of scope.
    Why it matters for enterprise value
    PIK features are common in growth and sponsor-backed capital structures; measurement drives earnings per share available to common holders.
    What to do now
    Check any PIK preferred instruments and the EPS calculation before fiscal 2027.
    Effective
    Fiscal years beginning after December 15, 2026; early adoption permitted. Issued April 2026.

    IASB · IFRS 18

    Presentation and Disclosure in Financial Statements (replaces IAS 1)

    Protect valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    New required operating, investing and financing categories and subtotals in the income statement, disclosure of management-defined performance measures in the notes, and stronger aggregation rules.
    Why it matters for enterprise value
    Adjusted metrics used in earnings calls move inside the audited financial statements with a reconciliation. IFRS reporters, and US groups benchmarked against them, get a new operating profit line.
    What to do now
    For IFRS entities, map current non-GAAP measures to the MPM rules and restate the comparative year; for US filers, prepare for peer comparisons on the new subtotals.
    Effective
    Annual periods beginning on or after January 1, 2027, applied retrospectively; early application permitted.

    IASB · IFRS 19

    Subsidiaries without Public Accountability: Disclosures

    Create valueUpcomingEffective Jan 2027Evidence grade D
    What changes
    Eligible subsidiaries of IFRS groups can apply IFRS recognition and measurement with reduced disclosures. August 2025 amendments extended the relief to standards issued through May 2024, including IFRS 18.
    Why it matters for enterprise value
    Less statutory reporting effort across a subsidiary footprint, with one set of numbers for group and local reporting.
    What to do now
    Identify eligible subsidiaries and whether local regulators permit IFRS 19, then cut the statutory disclosure set accordingly.
    Effective
    Annual periods beginning on or after January 1, 2027; early application permitted.

    FASB · ASU 2025-06

    Internal-use software (ASC 350-40) targeted improvements

    Create valueUpcomingEffective Jan 2028Evidence grade D
    What changes
    Removes the project-stage model. Software costs are capitalized once management has authorized and committed to funding the project and it is probable it will be completed and used as intended.
    Why it matters for enterprise value
    Iterative and agile builds, including AI and agentic tooling, fit the capitalization model better, which affects reported operating expense, EBITDA and the asset base.
    What to do now
    Map the AI and software build portfolio against the new threshold and agree the policy with the auditors before the build plan for 2028 is locked.
    Effective
    Annual periods beginning after December 15, 2027, including interim periods; early adoption permitted.

    FASB · ASU 2025-11

    Interim reporting (ASC 270) narrow-scope improvements

    Protect valueUpcomingEffective Jan 2028Evidence grade D
    What changes
    Adds a list of required interim disclosures and a principle to disclose material events since the last annual report. It does not change what interim reporting is for.
    Why it matters for enterprise value
    Quarterly disclosure becomes more uniform, so gaps relative to peers are easier to spot.
    What to do now
    Gap the current 10-Q note set against the new interim disclosure list before fiscal 2028.
    Effective
    Annual periods beginning after December 15, 2027, and interim periods within them; early adoption permitted.

    FASB · ASU 2026-02

    Environmental credits and environmental credit obligations (new Topic 818)

    Create valueUpcomingEffective Jan 2028Evidence grade D
    What changes
    Creates ASC 818 for the recognition and measurement of environmental credits (for example emissions allowances and renewable credits) and the obligations to remit them. Issued May 19, 2026.
    Why it matters for enterprise value
    Compliance credits and voluntary programs stop being accounted for by analogy, so the cost of carbon and the value of credits held show up consistently.
    What to do now
    Inventory credit programs and obligations and align the policy with the sustainability reporting team, which uses the same credits.
    Effective
    Public business entities: annual periods beginning after December 15, 2027. Other entities: after December 15, 2028.

    FASB · ASU 2026-03

    Fair value of equity securities with contractual sale restrictions (investment companies)

    Protect valueUpcomingEffective Jan 2028Evidence grade D
    What changes
    Amends ASC 820 for investment companies under ASC 946 that hold equity securities a contract prohibits them from selling. Entities outside ASC 946 are unaffected. Issued September 9, 2026.
    Why it matters for enterprise value
    Relevant to funds, corporate venture vehicles that report as investment companies, and token holdings with lockups; it changes reported fair value and NAV.
    What to do now
    If any entity in the group reports under ASC 946, identify locked-up positions and plan prospective adoption.
    Effective
    Annual periods beginning after December 15, 2027; early adoption permitted on or after September 9, 2026; prospective.

    FASB · ASU 2025-10

    Government grants (new Topic 832)

    Create valueUpcomingEffective Jan 2029Evidence grade D
    What changes
    First US GAAP recognition, measurement and presentation model for government grants received by business entities, separating grants related to assets from grants related to income.
    Why it matters for enterprise value
    Grant-funded capex and incentives (CHIPS, energy and state programs) will be presented consistently, which makes the return on subsidized investment easier to show.
    What to do now
    Catalogue grants and incentives currently accounted for by analogy and model the presentation change on gross margin and asset base.
    Effective
    Public business entities: annual periods beginning after December 15, 2028; early adoption permitted. Other entities: one year later.

    Tax regulations

    Treasury / IRS · IRC §55 (CAMT); Notices 2025-46, 2025-49, 2026-7

    Corporate alternative minimum tax: interim guidance

    Protect valueGuidance still movingEffective Jan 2023Evidence grade E
    What changes
    The 15% minimum tax on adjusted financial statement income for corporations averaging over $1 billion remains in force. Treasury and the IRS are partially withdrawing the 2024 proposed regulations and have issued interim notices, most recently Notice 2026-7 (February 18, 2026), which taxpayers may rely on.
    Why it matters for enterprise value
    CAMT ties cash tax to book income, so accounting choices (including the ASUs above) now carry a direct tax cost. The new expensing rules interact with it.
    What to do now
    Run CAMT alongside the regular-tax forecast, and have the controller and tax director review book-income-sensitive accounting policy changes together.
    Effective
    Taxable years beginning after December 31, 2022; interim guidance applies until revised proposed regulations are issued.

    Still moving: Revised proposed regulations have been announced but were not found published as of the review date. Positions resting on interim notices may change.

    US Congress · OBBBA — §174A

    Domestic research and experimental expensing restored

    Create valueIn forceEffective Jan 2025Evidence grade D
    What changes
    Domestic R&E costs paid or incurred after December 31, 2024 are deductible immediately. Taxpayers can elect to deduct unamortized 2022-2024 domestic costs in the first post-2024 year or over two years; eligible small businesses can apply the change back to 2022. Foreign R&E stays on 15-year amortization.
    Why it matters for enterprise value
    Reverses the cash-tax drag of capitalizing R&D, which hit software, AI and life sciences hardest, and creates a one-time catch-up deduction.
    What to do now
    Model the catch-up election (one year versus two) against expected taxable income and CAMT exposure, and revisit where R&D is performed given the domestic-versus-foreign split.
    Effective
    Amounts paid or incurred in taxable years beginning after December 31, 2024.

    US Congress · OBBBA — §163(j)

    Business interest limit returns to an EBITDA base

    Create valueIn forceEffective Jan 2025Evidence grade D
    What changes
    The 30% limit on business interest is computed on adjusted taxable income before depreciation and amortization again.
    Why it matters for enterprise value
    More interest is deductible for capital-intensive and leveraged businesses, which lowers the after-tax cost of debt and changes the optimal capital structure.
    What to do now
    Recompute the after-tax cost of debt in WACC and refinancing models, and release valuation allowances on carried-forward interest where now usable.
    Effective
    Taxable years beginning after December 31, 2024.

    US Congress · OBBBA (P.L. 119-21) — §168(k)

    100% bonus depreciation made permanent

    Create valueIn forceEffective Jan 2025Evidence grade D
    What changes
    Restores and makes permanent full expensing for qualified property acquired after January 19, 2025.
    Why it matters for enterprise value
    Capex is deducted in the year it is placed in service, which lowers cash taxes and raises the after-tax return on capital projects.
    What to do now
    Re-run capital allocation hurdle rates on an after-tax cash basis and pull forward projects where timing is flexible.
    Effective
    Property acquired after January 19, 2025.

    US Congress · OBBBA — ASC 740 enactment accounting

    Recognizing the 2025 tax act in the financial statements

    Protect valueIn forceEffective Jul 2025Evidence grade D
    What changes
    Tax law changes are recognized in the period of enactment (July 4, 2025), remeasuring deferred taxes and valuation allowances for the new expensing, interest and international rules.
    Why it matters for enterprise value
    The act moved deferred tax assets and the effective rate in the enactment quarter and continues to move them as elections are made.
    What to do now
    Document elections (§174A catch-up, bonus depreciation) and their deferred tax effects, and re-test valuation allowances each quarter.
    Effective
    Period that includes July 4, 2025 (enactment date).

    US Congress · OBBBA — §951A (NCTI, formerly GILTI)

    Net CFC tested income replaces GILTI

    Protect valueIn forceEffective Jan 2026Evidence grade D
    What changes
    The §250 deduction drops to 40%, for a 12.6% effective rate at the 21% corporate rate; the 10% return on tangible assets (QBAI) exclusion is removed; the deemed-paid foreign tax credit rises from 80% to 90%.
    Why it matters for enterprise value
    Low-taxed foreign earnings cost more, while high-taxed jurisdictions benefit from the larger credit. The foreign footprint's after-tax value shifts.
    What to do now
    Re-forecast the 2026 effective tax rate by jurisdiction and revisit expense allocation and foreign tax credit planning.
    Effective
    Taxable years beginning after December 31, 2025.

    US Congress · OBBBA — §250 (FDDEI, formerly FDII)

    Foreign-derived deduction eligible income replaces FDII

    Create valueIn forceEffective Jan 2026Evidence grade D
    What changes
    The deduction is set at 33.34%, a 14% effective rate, and is no longer reduced by a deemed 10% return on tangible property. Gains on certain dispositions of property and intangibles after June 16, 2025 are excluded.
    Why it matters for enterprise value
    Serving foreign customers from US-held IP and assets is rewarded more consistently, which supports onshoring intangibles.
    What to do now
    Quantify FDDEI for export revenue and weigh it in IP location and supply-chain decisions.
    Effective
    Taxable years beginning after December 31, 2025.

    US Congress · OBBBA — §59A (BEAT)

    Base erosion and anti-abuse tax set at 10.5%

    Protect valueIn forceEffective Jan 2026Evidence grade D
    What changes
    The BEAT rate is set permanently at 10.5% for applicable taxpayers with $500 million or more in average gross receipts, instead of the scheduled increase.
    Why it matters for enterprise value
    Related-party payments abroad remain a cash-tax exposure for large groups, at a known rate.
    What to do now
    Re-test BEAT exposure on intercompany service, royalty and interest flows after the NCTI and FDDEI changes.
    Effective
    Taxable years beginning after December 31, 2025.

    OECD Inclusive Framework · Pillar Two Side-by-Side package (January 5, 2026)

    Global minimum tax: side-by-side system for US-parented groups

    Protect valueGuidance still movingEffective Jan 2026Evidence grade E
    What changes
    Adds a Side-by-Side Safe Harbour and a UPE Safe Harbour that switch off the income inclusion rule and undertaxed profits rule for groups headed in qualifying jurisdictions, a permanent simplified effective-tax-rate safe harbour, and a one-year extension of the transitional CbCR safe harbour. Qualified domestic minimum top-up taxes still apply. A September 2026 package updated the GloBE Information Return.
    Why it matters for enterprise value
    US-parented groups avoid most IIR and UTPR top-up, but local minimum taxes and Pillar Two filings remain, so the compliance and data burden persists.
    What to do now
    Confirm safe-harbour eligibility for each jurisdiction, keep QDMTT and GloBE Information Return data flows running, and budget for 2024-2025 obligations that the package does not remove.
    Effective
    Fiscal years beginning on or after January 1, 2026; Pillar Two obligations for fiscal 2024 and 2025 remain.

    Still moving: Each jurisdiction must reflect the package in local law, and the OECD has committed to a stocktake concluding by 2029 that may change the side-by-side system.

    For the CAO and controller ·

    Expensing, CAMT and software capitalization: the controller's read

    The 2025 tax act lets companies deduct domestic software and AI build costs at once. ASU 2025-06 changes when the same costs are capitalized on the books. For a company in CAMT range, the gap between the two is now a cash-tax line, and it belongs to the controller as much as to tax.

    Three clocks on one cost

    A dollar spent building internal software or an AI capability now runs on three clocks. For regular tax, domestic software development is research and experimental spending, and section 174A lets it be deducted in the year it is paid or incurred, for tax years beginning after December 31, 2024. Foreign development stays on 15-year amortization.

    On the books, ASC 350-40 as amended by ASU 2025-06 capitalizes internal-use software once management has authorized and committed funding and completion is probable, then amortizes it over its useful life. The standard is effective for annual periods beginning after December 15, 2027, with early adoption permitted.

    For the corporate alternative minimum tax, the starting point is adjusted financial statement income, which follows the books. So the same build cost is deducted at once for regular tax, spread over several years on the books, and spread over the same years for CAMT.

    Rules: OBBBA — §174A, ASU 2025-06, IRC §55 (CAMT); Notices 2025-46, 2025-49, 2026-7

    Where CAMT bites, and where it does not

    CAMT applies to corporations whose average adjusted financial statement income over three years exceeds $1 billion, at 15% of that income, and is owed only to the extent it exceeds regular tax. Anything that lowers regular tax without lowering book income moves a company toward paying CAMT.

    Bonus depreciation on qualified property is largely neutral here: the CAMT rules replace book depreciation on tax-depreciable property with tax depreciation, so 100% expensing of servers, data-center equipment and other qualifying hardware reduces both measures. Section 174A expensing has no such adjustment. A software or AI build deducted at once for regular tax still reaches CAMT income only as the books amortize it, which widens the gap between the two taxes in the build years.

    That makes the mix of an AI program matter. Purchased compute and hardware ride bonus depreciation in both measures. Internally developed software and model work ride 174A for regular tax only.

    Rules: OBBBA (P.L. 119-21) — §168(k), OBBBA — §174A, IRC §55 (CAMT); Notices 2025-46, 2025-49, 2026-7

    Why ASU 2025-06 is now a tax decision

    Removing the project-stage model means agile and iterative builds, which often never had a clean application-development stage, can be capitalized once the funding and probability tests are met. More cost capitalized, or capitalized earlier, lowers book expense now and raises it later as amortization.

    For a company paying regular tax only, that is a presentation question. For a company near its CAMT crossover, it moves CAMT income, and the adoption date and transition method shift which years carry the higher amortization. The policy choice and the tax forecast should be made together, before the 2028 build plan is locked.

    Rules: ASU 2025-06, IRC §55 (CAMT); Notices 2025-46, 2025-49, 2026-7

    What lands in the tax provision

    The tax act was enacted on July 4, 2025, so its effects were recognized in the period that includes that date. Companies that had built deferred tax assets for capitalized research costs under the pre-2025 rules saw those assets reverse as the catch-up deductions became available, and new book-capitalized software that is expensed for tax now creates a deferred tax liability.

    CAMT itself is a period cost. Under the FASB staff's guidance an entity may elect whether to consider CAMT when it assesses whether deferred tax assets will be realized, and should apply that policy consistently. ASU 2023-09's expanded rate reconciliation and taxes-paid disclosures will show these movements to investors, so the narrative should be agreed before the numbers are published.

    Rules: OBBBA — ASC 740 enactment accounting, ASU 2023-09

    Illustrative arithmetic, year one

    Round inputs, not a forecast for any company: a $100.0M domestic software and AI build, 80% capitalized on the books and amortized straight line over 3 years, the rest expensed.

    Regular-tax deduction (174A)
    $100.0M
    Book charge, which CAMT income follows
    $46.7M
    Deduction regular tax gets and CAMT does not
    $53.3M
    That gap at the 15% CAMT rate
    $8.0M

    The last line is the most CAMT this gap alone can add in year one. Whether any CAMT is owed depends on the whole company: average adjusted financial statement income above $1 billion, and CAMT above regular tax. In later years the books keep amortizing while the tax deduction is spent, so the gap reverses.

    What to do this quarter

    1. Build one cost map for the software and AI portfolio that labels every cost line three ways: book treatment under ASC 350-40 as amended, regular-tax treatment (domestic 174A expensing, foreign 15-year amortization, or bonus-eligible hardware), and CAMT treatment.
    2. Run the CAMT crossover alongside the regular-tax forecast every quarter, with the build schedule as an input, not an afterthought.
    3. Choose the 174A catch-up election (one year or two) against the CAMT forecast, not against regular tax alone.
    4. Decide the ASU 2025-06 adoption date and transition method with the tax director in the room, and test the effect on CAMT income for each year it touches.
    5. Agree the deferred tax mapping for capitalized software and the CAMT policy election with the auditors, and draft the rate-reconciliation narrative early.

    This is Koko's reading of published rules, reviewed on the date shown. It is not accounting or tax advice. CAMT guidance is still interim (see the CAMT row above), and every position here should be confirmed with your tax advisers and auditors.

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