Key takeaways:

• • • Deploying AI and governing it are two different things 鈥� Most tax, audit & accounting firms are further along on deployment of AI than they are with setting up how it will be governed.

    • AI literacy and understanding will be key attributes 鈥� The skill that will define the next generation of auditors isn’t knowing how to use AI; rather, it’s knowing when to distrust it.

    • Risk assessment needs to be re-thought 鈥� The risk assessment gap is a structural problem, not a technology maturity problem. And no better model is going to fix it.

There is a version of AI adoption that looks like progress, but isn’t. It involves a pilot program that runs well, gains a positive internal review and a mention in the firm’s next thought leadership piece 鈥� and then nothing changes throughout the firm. The workflow that got automated stays automated, and everything else stays the same.

This pattern is more common than many tax, audit & accounting firms want to admit. The organizational work that scaling AI actually requires 鈥� such as deciding who owns the outputs, redesigning quality review, working out what happens when a model gets something wrong 鈥� doesn’t surface in a pilot. Instead, it surfaces in production. And those firms that have been running the same pilot for more than a year aren’t being cautious, they鈥檙e simply avoiding those decisions.

A recent survey by tech market research group International Data Corp. (IDC) of 1,005 audit and accounting professionals globally captures the gap precisely. The study showed that two-thirds of firms have AI embedded in strategy or underway in pilots, but only 7% . That distance between deployment and readiness is where most of the real work is hiding.

The audit profession is underinvesting in a key skill

Ask most audit firm leaders what skills their people need for an AI-driven practice, and the answers come back quickly: data analysis, AI literacy, and technology proficiency. Those aren’t wrong answers, but they’re incomplete in a way that matters.

The skill that will actually define audit quality in an AI-enabled environment isn’t the ability to use the tools; rather, it鈥檚 the ability to pressure-test what those tools produce. To read an AI-generated summary and identify what it might have missed, or to recognize when a flagged pattern in a data set is just noise rather than a red flag, or even to override a confident-sounding output when professional judgment says something doesn’t add up.

That’s closer to editing than accounting 鈥� and it’s a fundamentally different capability than simply being familiar with AI systems. Yet most re-skilling programs are building that familiarity, while it鈥檚 the understanding and judgment that separates auditors who use AI well from auditors who use it credulously.

Indeed, excessive trust in AI outputs is the specific failure mode the profession needs to train against 鈥� and that鈥檚 not getting enough attention.

The risk assessment problem is permanent

There’s a version of the AI-in-audit story in which every limitation is temporary 鈥� the AI models will improve, the training data will get better, the accuracy will increase. For most audit applications, that’s probably true, but for risk assessment, it isn’t.

Risk assessment requires professional skepticism: the trained disposition to question, probe, and not accept appearances at face value. AI models are trained to find patterns and produce coherent, confident output. Those two orientations are in direct tension. A model that identifies a pattern and presents it with confidence is doing exactly what it was designed to do. However, the problem is that professional skepticism sometimes requires distrusting precisely that kind of coherent, confident output 鈥� and then asking what the pattern is missing, who might be motivated to produce it, and whether the data behind it can be trusted.

That gap isn’t a technology maturity problem. It’s a structural problem. Nearly 80% of audit leaders in the IDC survey say they recognize the risk of algorithmic bias in functions like risk assessment and fraud detection 鈥� and that recognition points at something real. The right response isn’t to avoid AI in risk assessment entirely, of course, but it is to be clear-eyed about where AI’s role ends and where the auditor’s begins. Summarizing, flagging, and organizing are appropriate uses of AI, but the judgment about what the output means belongs with someone else.

Governance that actually means something

Most tax, audit & accounting firms have an AI policy; however, far fewer have built the infrastructure that makes it operational.

The two requirements that matter most are traceability and explainability. Traceability means that every AI output cites its source 鈥� if it can’t show its work, the firm shouldn’t rely on it. Explainability means the auditor who is reviewing the output can follow the reasoning and form an independent view of whether it holds together. Both of these concepts should be requirements, not preferences. The audit partner signing the report needs to be able to stand behind every conclusion in it, and that requires being able to read the chain from input to output.

Naturally, the more difficult governance question is what “human in the loop” actually means when the processes are operational. As a principle, everyone agrees that the “human in the loop” is critically important. However, as a set of design decisions 鈥� determining at which specific points in a workflow human judgment required, how does the interface prompt it, and who is accountable when it doesn’t happen 鈥� most firms haven’t worked that out. That kind of imprecision is where audit risk can accumulate quietly.

Where AI is genuinely earning its place

None of this is an argument against AI in audit, of course. Document extraction, first-draft writing, data summarization are all areas in which AI is delivering real value, and the gains aren’t marginal. Contracts that once took days to review can be turned around in hours. Workpaper summaries and client communications that traditionally consumed senior staff time are now being handled in the first-draft stage by tools that do it well. Those hours are going back to partners and managers, and their work is better for it.

The honest picture of AI in audit is not the hype version 鈥� transformational overnight, replacing roles, reshaping everything at once. Instead, it’s more incremental than that, more uneven, and more dependent on organizational decisions than technology ones. The audit firms making the most of it aren’t the ones that moved fastest; rather, they’re the ones that were clearest about what they were trying to solve, built governance structures that could handle the friction, and invested in the human judgment that AI can support but cannot replace.

That clarity 鈥� about what AI is good for, what it isn’t, and what it requires of the people using it 鈥� is where the real work is.

You can find more about the challenges facing audit service professionals here

Key takeaways:

• • • The 2027 end date is not a runway 鈥� The One Big Beautiful Bill sets a statutory de minimis end date of July 1, 2027, but its own legislative history explicitly preserves the president鈥檚 authority to restrict it before that date. Sellers banking on a two-year transition period are reading the headline, not the fine print.

    • The Supreme Court win didn鈥檛 save the refunds 鈥� The Supreme Court鈥檚 IEEPA decision was real, but the administration switched legal authority to Section 1321 and kept the suspension running. Combined with congressional cover from the One Big Beautiful Bill, the path to recovering tariffs already paid is genuinely uncertain 鈥� not just delayed.

    • The refund clock just reset 鈥� The lead test case for processing refunds through CBP鈥檚 KAPE system, Atmos, just settled, forcing the process to restart with a new test case. Sellers waiting on refunds are further back in the queue than they realize.

Most e-commerce merchants couldn鈥檛 have told you what de minimis meant two years ago 鈥� mostly because they didn鈥檛 need to. It was the invisible infrastructure of cross-border trade, the threshold below which imported goods pass through customs without duties or taxes. And in the United States, that threshold sat at $800. For small online sellers sourcing internationally, it wasn鈥檛 a technicality 鈥� it was their business model. Now, that model is over.

De minimis was deliberate trade policy built on simple logic: the cost of collecting duties on a $25 phone case exceeds the revenue it generates. Let low-value goods flow freely, the thinking went, and e-commerce would grow 鈥� and it did.

The Trump administration鈥檚 first moves targeted Canada, Mexico, and China on fentanyl-related grounds. Then came Executive Order 14324, suspending duty-free de minimis for all countries effective August 29, 2025. Sellers who had never filed a customs entry suddenly had to file informal entries for goods valued up to $2,500 鈥� and pay tariffs on every single one. Last count, that has meant $175 billion in tariffs paid annually, with small shipments accounting for roughly 63% of that.

The legal basis for Trump鈥檚 tariffs 鈥� the International Emergency Economic Powers Act (IEEPA) 鈥� went to the Supreme Court, which constrained presidential authority to pass these tariffs. Many sellers took that as a signal that tariff refunds were coming 鈥� they shouldn鈥檛 have.

Then came the legislative layer that changed everything. The One Big Beautiful Bill Act (OBBBA) 鈥� H.R. 1, now law 鈥� codifies the end of de minimis under Title 19 with a statutory end date of July 1, 2027. Buried in the legislative history, however, is language explicitly stating that nothing in the bill limits the president鈥檚 existing authority to restrict de minimis before that date. The current suspension has congressional cover, meaning that any court challenge faces a much tighter call than it would have had a year ago.

What most sellers are getting wrong

What鈥檚 making matters worse, however, is that many small e-commerce merchants may not fully understand all the nuances of the laws and regulations they are trying to navigate. Indeed, there are certain aspects of the situation that many are getting wrong, including:

The 2027 date is a headline, not a lifeline 鈥� When the ne Big Beautiful Bill passed with a July 1, 2027, , many sellers assumed they had a transition period 鈥� time to adjust pricing, renegotiate supplier terms, and build a compliance infrastructure. Buried in House Report 119-106, however, is language explicitly stating that nothing in the bill limits the president鈥檚 existing authority to restrict de minimis before that date. Congress didn鈥檛 create breathing room; rather, it codified the end while leaving the accelerator fully intact. The 2027 date is when de minimis ends by law. Indeed, it could end sooner 鈥� and effectively already has.

The Supreme Court decision didn鈥檛 unlock refunds 鈥� The Court鈥檚 IEEPA ruling was significant, but the administration鈥檚 response was swift: reimposed the suspension of tariffs under Section 1321 authority as of February 24. The tariff meter never stopped; and now, with the OBBBA鈥檚 legislative history providing congressional cover, the 鈥� which specifically addresses whether sellers are entitled to refunds in the de minimis context 鈥� faces a much harder statutory construction argument than it would have a year ago. This may mean that the Supreme Court win was a legal victory that may not translate into money back.

The refund process just lost its test case 鈥� For sellers hoping to recover duties paid, the most practical path was through the KAPE system run by the U.S. Customs and Border Protection (CBP) 鈥� a workaround allowing refund claims to feed directly into an听听for verification. The lead case proving out that process, , just settled. Now, the trade legal community has to start over with a new test case, and nobody knows how long that is going to take. Sellers who filed protests rather than complaints at the Court of International Trade (CIT) are in a particularly difficult position 鈥� protests have time limits, and the CBP is under court order to re-liquidate open ones. Which legal bucket your entries fall into matters enormously right now.

The bottom line

The de minimis era enabled a generation of small merchants to compete globally on terms that would have been unimaginable 20 years ago. Its sunset doesn鈥檛 mean the end of cross-border e-commerce 鈥� but it does mean the end of operating on assumptions. The 2027 date, the Supreme Court decision, the refund process 鈥� each looked like relief and turned out to be more complicated than the headline suggested.

E-commerce merchants impacted by these de minimis developments need to talk to a trade attorney 鈥� not for the basics, but to understand where your claims stand, whether your protest strategy is still viable, and what the Atmus settlement means for you.

The storm isn鈥檛 over 鈥� and it may be more complicated than most sellers have been told.

For more on this, please tune into the 成人VR视频 Institute鈥檚 recent 鈥淐larity鈥� podcast, featuring , about the challenges facing small e-commerce merchants today

Key takeaways:

• • • Profits continue to be strong 鈥� Most tax & accounting firms saw revenues and profits increase in 2025 despite a chronic talent shortage and other systemic challenges.

    • Optimism around AI adoption 鈥� Tax professionals are generally optimistic about AI-enhanced technologies, and their firms are backing their optimism with unprecedented levels of investment.

    • Expansion of advisory services 鈥� Firms are expanding their advisory service offerings to clients in such areas as tax strategy and business consulting, fueling growth and providing opportunities for competitive differentiation.

Tax, audit & accounting firm professionals have been concerned for years that the one-two punch of do-it-yourself tax software and automation might eventually erode the value of 鈥攁nd demand for 鈥� their services. However, according to the 成人VR视频 Institute鈥檚 “2026 State of Tax Professionals Report”, which surveyed more than 600 tax professionals worldwide, firms of all sizes are adapting remarkably well to the current era of rapid technological change and political upheaval.

Indeed, tax professionals surveyed say that, in addition to traditional tax preparation, their customers want and need more advisory services, a trend that has been gaining momentum for several years. In response, many firms are continuing to expand their service offerings in the areas of tax strategy, business consulting, decision support, and financial planning 鈥� especially at larger firms with more abundant resources.

The result of this gradual shift in service offerings is that profit margins for tax & accounting firms worldwide averaged about 30% in 2025, with some firms registering profit margins of more than 40%.

Efficiency and growth were top strategic priorities

When asked about their top strategic priorities for the coming year, survey respondents cite efficiency and promoting firm growth as the top factors on the strategic agenda for 2026, even more emphatically than they did in 2025.

Further, they see that making more and better use of technology is still the most immediate path to greater efficiency, 听which is why introducing additional automation and AI 鈥� or just trying to get the most out of a firm鈥檚 existing technology stack 鈥� was also mentioned as an important focus for the upcoming year.

Still searching for solutions to talent challenges

Challenges still abound, however. An anemic pipeline of new talent and the ongoing retirement of senior personnel are among the top barriers to progress and profitability at many firms, the report indicates. The report also notes that the resulting competition for qualified candidates leads to overwork, skills gaps, and capacity restraints, all of which can impede a firm鈥檚 ability to compete and grow.

Many respondents say their firms are using multiple strategies to address these issues, including more targeted training, career development, outsourcing, task reallocation, and automation. Competition for top talent is intense, nevertheless; and the report shows that midsize tax firms may feel the talent squeeze harder than others, chiefly because larger firms can offer higher salaries and more career opportunities to retain top talent.

Another way firms are addressing their talent challenges is by automating more tax processes and workflows; however, the report also suggests that many firms have reached the point in their technological maturity at which it may be more difficult to identify additional processes to be automated. As a result, these firms find themselves in somewhat of a holding pattern, unable to advance technologically because of unyielding systemic and cultural impediments.

Meanwhile, many larger firms have already built the technological infrastructures they need to support more advanced forms of automation and data analysis. Now, the report reveals, these firms are shifting their focus to make better use of workflow-enhancing tools that can enable more efficient operations, expand their firm鈥檚 capabilities, and serve as a competitive differentiator.

Not surprisingly, the conversation around AI is heating up as well. While tax professionals may not be so interested in public chatbots such as Claude and ChatGPT, their attention is directed toward the many ways in which AI can enhance the tools they already use and how intelligent deployment of these tools can benefit their firms. Indeed, AI was the only category of technological investment which experienced year-on-year budget growth, the report shows.

Overall, the “2026 State of Tax Professionals Report” offers invaluable insight into where tax professionals see their firms and their industry now, shedding light on how the world鈥檚 top tax leaders are advancing the profession.

You can download a free copy of the full 成人VR视频 Institute 鈥�2026 State of Tax Professionals Report鈥� by filling out the form below:

Key takeaways:

• • • Mandatory compliance mandates are growing 鈥� Pillar 2, DAC6, and other real-time reporting mandates are increasing obligations in dozens of jurisdictions today, and those tax departments without the infrastructure to meet these obligations are already behind.

    • Real-time documentation is critical 鈥� The window between a transaction occurring and a tax authority scrutinizing it is shrinking to near zero in some markets, meaning that documentation must exist at the moment it is generated, not reconstructed afterward.

    • Data quality is compliance quality 鈥� Real-time compliance brings with it heightened pressure to avoid incomplete or inconsistent inputs, because increasingly sophisticated analytics used by tax authorities will find them.

In 2023, a major European manufacturer was hit with a seven-figure penalty not because its tax return was wrong, but because it couldn’t demonstrate how it arrived at the right answer. No documented governance framework, no clear ownership, and no audit trail. The numbers were defensible, but the process wasn’t.

That gap 鈥� between getting the right answer and being able to prove it 鈥� is where corporate tax risk now lives.

Governments and tax authorities worldwide are to self-report accurately. They are building legal frameworks, digital infrastructure, and enforcement mechanisms to verify compliance in real time. And for tax departments accustomed to managing compliance on their own terms, the window for a comfortable transition is closing fast.

A global tightening

Tax governance requirements are intensifying on multiple fronts. In the United States, for example, the IRS’s Large Business & International division has significantly expanded its compliance campaigns, targeting transfer pricing, research & development (R&D) credits, and multinational structures. Section 174 of the 2017 Tax Cuts and Jobs Act now requires companies to amortize R&D expenditures over five or 15 years depending on where research occurs 鈥� a change that many tax departments are still working through while absorbing new obligations on top of it.

Internationally, the pace is faster still. The framework that the Organisation for Economic Co-operation and Development (OECD) created for its base erosion and profit shifting (BEPS) rules has been adopted by more than 135 countries. Pillar 2 鈥� the global 15% minimum corporate tax rate 鈥� is already in effect in dozens of jurisdictions and is actively reshaping how multinationals structure their tax affairs. These are not coming changes 鈥� they are current ones.

Mandatory disclosure regimes have expanded in parallel. The European Union’s DAC6 directive requires intermediaries and taxpayers to report potentially aggressive cross-border arrangements, with penalties in some member states reaching hundreds of thousands of euros. The United Kingdom’s Senior Accounting Officer regime goes even further, placing personal legal accountability on named senior executives for the adequacy of their company’s tax accounting arrangements. Similar regimes are expanding in Australia, Canada, and Brazil.

These are not isolated experiments. They represent that is not going to reverse any time soon.

The real-time reporting challenge

That means, corporate tax departments must respond to this shift because the traditional audit model 鈥� authorities review historical returns and request documentation years later 鈥� is being replaced in a growing number of markets. Spain, Hungary, and South Korea already require taxpayers to submit transactional data directly to tax authorities through mandatory electronic systems. The EU’s Value added tax (VAT) in the Digital Age initiative will extend similar requirements across all 27 member states beginning in 2028.

For tax departments, this reporting compression is the central operational challenge of the next five years. A team that once had 12 to 18 months to reconstruct documentation for an audit now needs that documentation to be accurate and defensible at the moment it is generated. That requires a fundamentally different operating model 鈥� not just better record-keeping, but automated data capture and real-time reconciliation built into core financial systems 鈥� along with the ability to transfer that documentation electronically in real time.

3 actions tax departments must take now

To begin to address this dramatic change, corporate tax departments need to act now, taking steps that include:

1. Building a formal governance framework

Tax departments need written governance frameworks that clearly define what party owns each compliance decision, how decisions are reviewed and approved, and what controls exist to catch errors before filing. This means named ownership of obligations, documented sign-off processes, and regular internal reviews against a compliance calendar.

In the UK, this is already a legal requirement ; and similar standards are emerging in Germany, Australia, and across the EU. A framework should cover at minimum; the ownership of each material filing obligation; the review and approval chain for positions taken; escalation procedures for uncertain tax positions; and a schedule for internal control testing. Without these processes in place, tax departments could face regulatory penalties, personal liability for senior leaders, and reputational damage that may be difficult to recover from.

2. Fixing the data access problem

Tax departments consistently lack reliable, timely access to the financial data they need. This is primarily an organizational problem, not a technology one. Tax functions often sit downstream from finance systems designed without tax requirements in mind 鈥� meaning data often arrives aggregated, reclassified, or stripped of the granularity needed for compliance work.

Solving this requires tax leaders such as finance, IT, and business operations 鈥� not just to request data, but to influence how that data is captured at its source. That means participating in enterprise resource planning implementations, establishing data requirements for new business lines before they launch, and building direct feeds from source systems rather than relying on manual extracts.

3. Treating data hygiene as a compliance control

Tax authorities in the UK, the Netherlands, Germany, and the US are deploying advanced analytics to identify anomalies in corporate filings. Unexplained variances between statutory accounts and tax returns, inconsistencies in intercompany pricing, or mismatches between VAT and corporate income tax data could all trigger closer scrutiny.

Data hygiene must be treated as a compliance control, not an IT issue. In practice that means establishing reconciliation checkpoints between source data and tax inputs, maintaining documented data lineage so any figure in a return can be traced to its source, and conducting data quality reviews before filing deadlines 鈥� not after.

The bottom line

The regulatory trajectory is set, so that means the question for tax leaders whether their department will be ready when tested. Governance, data access, and data quality are no longer back-office concerns 鈥� they are the foundation upon which defensible compliance is now built.

Tax department leaders need to build that foundation now, before the examiner asks.

You can find out more about

Key insights:

• • • Real-time tax compliance has restructured the tax function 鈥� Dozens of nations now require structured invoice data in real time, with the EU mandating cross-border digital reporting by 2030. The traditional file-and-wait audit cycle is gone now, replaced by clearance regimes that can freeze multi-million-dollar invoices for nonconforming data.

    • Regulators have pulled ahead of the businesses they oversee 鈥� Tax authorities in mature CTC jurisdictions now arrive at audits with structured transaction data already processed by their own analytics. Government turnaround times that took months now take weeks, forcing multinational tax leaders to compress multi-year roadmaps into 12- and 18-month cycles to keep up.

    • The lessons travel beyond tax 鈥� There are two ways to lose this race: Outrun your own controls or surrender entirely. Both showed up in Las Vegas, and both will show up in every other regulated profession over the next decade.

LAS VEGAS 鈥� The听 sold out. A guest list that included tax directors from Amazon, Walmart, and Procter & Gamble, OpenAI’s tax department, the Big Four, 成人VR视频 and every other major tax software provider in the market spent three days at the Aria with pool deck, casino floor, and restaurants worth lingering over all a few steps away.

The room had every reason to spend its evenings somewhere else other than a sunless conference room talking about tax. Yet almost no one did. They were too busy grappling with an arms race the corporate audit side had begun to suspect it was losing.

And it鈥檚 one they cannot afford to lose.

End of the traditional model

The arms race is real-time tax compliance, and it has dramatically restructured the ground beneath the tax profession in less than a decade. By April, more than 60 jurisdictions have moved or are moving to continuous transaction controls. Italy and Hungary were early; Poland, France, Belgium, Brazil, Saudi Arabia, India, and Singapore are now operational or imminent, and countries like Spain, Germany, the United Kingdom and the United Arab Emirates are on the way. The European Union has locked onto a 2030 deadline for cross-border real-time digital reporting and a 2035 backstop for harmonizing what’s left.

The traditional model 鈥� issue an invoice, file a return weeks later, audit when the auditor gets around to it 鈥� no longer exists in those jurisdictions. Tax authorities now see the transaction as it happens, validates it in structured form, and pre-fills the return on the taxpayer’s behalf.

What this new process has done to the tax function is fundamentally alter its structure in a way leaves practitioners reeling. The job used to be a craft of Excel, judgment, and institutional memory. Now, at the high end, it has become as much a data science problem as an accounting one.

The arms race is real-time tax compliance, and it has dramatically restructured the ground beneath the tax profession in less than a decade.

Attendees at TEI鈥檚 2026 Tax Technology Seminar polled themselves on tooling, and the answers came back as a list of data pipelines that dozens of attendees seemed to favor: Alteryx, Power Platform, Snowflake, Databricks, Microsoft Fabric, & Palantir Foundry. These platforms are running agentic AI systems against historical filings, deploying validation agents to critique their own outputs, and using AI-driven image-to-text solutions to pull structured data out of state tax notices that never arrive in the same format twice. They are data integration pipelines in 15 minutes that would have sat in an IT queue for two months before being answered.

They have little choice as the stakes are far higher and the challenges far more demanding than they used to be. In a clearance regime, an invoice has no legal force until the tax authority returns its identifier. Did you submit the wrong VAT ID, malformed schema, or mismatched master data? Congratulations! Your invoice is rejected. That means the truck doesn’t move, the buyer doesn’t pay an invoice that may be in the millions of dollars and then the penalties stack on top. Italy, for instance, charges a fee of 70% of the disputed VAT.

And then there are the audits.

Outgunned

The audit isn’t an occasional event anymore. In government jurisdictions with mature continuous-transaction-control tax regimes, it is a conversation that started weeks before the auditor walked in, on data their analytics had already processed.

A speaker on a seminar panel led by Deloitte and 成人VR视频 described the dynamic plainly: Tax authorities in those jurisdictions have arrived at audits already knowing more about the transactions than the companies and their in-house audit teams sitting across the table. Not because anyone is hiding anything, but because the data arrived at the tax authority in structured form, in real time, and the authority had run its analytics on it before the meeting was even on the calendar. One panelist said this represents “a shift from us preparing returns to us answering notices on the data that’s been shared.”

What the room kept circling around, however, was that regulators have not just kept pace with their counterparties, they鈥檝e now pulled ahead. Singapore, one panelist noted, is doing more with AI than even major companies. Indeed, government turnaround times that used to take months are now closing in weeks, which is forcing multinational tax leaders to compress their multi-year roadmaps into 12- and 18-month cycles 鈥� not because they want to but because their counterparties already had.

The lesson that corporate tax functions have been forced to absorb is that there are two ways to lose this race, and both were on display at TEI鈥檚 2026 Tax Technology Seminar as cautionary tales.

This asymmetry is structural, and that is what makes it an arms race rather than a transition. There is no version of this dynamic in which the company being audited wins by being more careful, more thorough, or more well-prepared at the end of the quarter. The advantage now accrues to the side with the fastest and cleanest pipelines, that runs the smartest AI, and that understands the way these increasingly complex systems interact. Increasingly, that winning side is the government. And, more alarming, this isn鈥檛 just a problem for this particular industry 鈥� tax just happened to get here first. However, it鈥檚 coming for everyone.

Two ways to lose

The lesson that corporate tax functions have been forced to absorb is that there are two ways to lose this race, and both were on display at TEI鈥檚 2026 Tax Technology Seminar as cautionary tales. The first is to outrun your own controls. AI coding tools that let a tax analyst build a working data integration pipeline in 15 minutes are genuinely valuable; they also let that same analyst deploy something nobody else has reviewed, documented, or knows how to maintain. An OpenAI panelist conceded the point when an audience member asked about the security implications of vibe coding 鈥� clearly, a new capability is also a new problem.

The second way to lose is harder to talk about. One panelist described, to attendees鈥� general dismay, hearing of companies that have given up on compliance entirely 鈥� instead, they pad their numbers with a safety margin and treat the eventual audit as the cheaper of the two costs. The panel recoiled 鈥� one member responded with a flat “Do not do this.” However, the anecdote landed because it isn’t theoretical. When the gap between what regulators can see and what your team can produce becomes wide enough, surrender starts to look rational.

Playing to win

Of course, the attendees at TEI鈥檚 2026 Tax Technology Seminar were not surrendering. If they were, they’d have been at the pool deep into their third cocktail. Or they’d have been on the casino floor or were about to catch an afternoon show. Instead, day after day, the tables filled, the exhibit hall ran hot, and the room was buying, listening, and building.

The game has changed and the stakes have risen 鈥� and the room is dead set on playing to win.

You can find more of听our coverage of Tax Executives Institute events here

• • • The reactive phase is partly a mindset problem 鈥� More than half of tax departments remain stuck in reactive, compliance-focused operations, not only because of frozen budgets, but because of cost-center thinking that shapes cost-center behavior.

    • The value is there, but the measurement isn’t 鈥� Two-thirds of tax professionals say their department鈥檚 technology investment has already enabled more strategic work; yet 22% say they track no performance metrics at all, making that value invisible to the people who control the budget.

    • The rebrand starts internally 鈥� With AI integration timelines compressing to between 1 and 2 years, tax departments that shift their posture now by measuring wins, designating leadership, and building the business case will be better positioned to lead 鈥� and those that don’t will fall further behind, faster.

Apart from the sales department, most other departments within a business are simply viewed as a cost center, and the tax department is no exception. However, like so much of that thinking, this view isn鈥檛 quite accurate because it is the tax department that can uncover the most savings for the business.

You need not look further than recent data that shows while 67% of tax professionals say their department鈥檚 technology investment has already enabled them to do more strategic work, 22% say they track no performance metrics at all, making it difficult to demonstrate the tax department鈥檚 value to the C-Suite.

Given this, it鈥檚 somewhat unsurprising that this cost-center view persists. Worse yet, is often internalized by in-house tax teams themselves. It is one thing to be viewed and treated as a cost center but to act like one is a different matter.

So, what if the bigger problem isn’t how the rest of the business views the tax department but instead how the department views itself?

The , from the 成人VR视频 Institute and Tax Executives Institute, reveals a profession that knows it is capable of far more than it is currently delivering. And yet the same patterns repeat: Budgets stay flat, technology adoption stays slow, and a majority of departments remain stuck in a reactive phase in regard to their technological development that has “remained stubbornly consistent over the past few years,” according to the report.

That’s not just an organizational failure; rather, that’s a mindset problem 鈥� and it starts from within the tax department.

The choices we keep making

The report outlines a Technology Maturity Curve that maps a progression in tech development from chaotic through reactive, proactive, optimized, and predictive stages.

This year, 64% of respondents placed their tax department at the chaotic or reactive end of the spectrum 鈥� up from 57% last year. The reactive phase is the operational definition of a cost center: Heads-down, output-focused, and disconnected from the broader business.

The report reveals something even more important. In those cases in which the budget isn’t the primary constraint, behavior doesn’t change. Almost one-third of respondents (32%) said their strategy for addressing capacity constraints is process optimization 鈥� without new technology or additional hiring. Not because they can’t pursue more, but because that’s the default mode.

One respondent put it plainly: “鈥ur company as a whole is making significant changes, but the tax department is typically an afterthought in those decisions.”

This raises a question that鈥檚 worth asking: Who taught the company to treat tax as an afterthought?

There鈥檚 evidence showing that tax departments are more

The data to challenge the cost-center identity isn’t missing; rather, it’s just not being captured or communicated to the C-Suite.

Two-thirds of respondents (67%) said their tax department鈥檚 technology investment over the past three years has already enabled a shift toward more strategic, proactive work, such as data analytics, forecasting, risk assessment, and decision-making support. Among larger departments, nearly half (48%) are now spending more time on these higher-value activities. This clearly shows that companies that have invested in tax automation are reporting real results, such as improved accuracy, reduced errors, lower costs, and streamlined workflows.

And yet, 22% of tax departments track no technology performance metrics at all, according to the report 鈥� not time savings, not error reduction, not ROI. Nothing.

While 67% of tax professionals say their department鈥檚 technology investment has already enabled them to do more strategic work, 22% say they track no performance metrics at all, making it difficult to demonstrate the tax department鈥檚 value to the C-Suite.

That is cost-center thinking in action 鈥� the belief that it鈥檚 the job of the tax department to do the work, but not to prove its value. However, what isn’t measured can’t be communicated 鈥� and what can’t be communicated can’t change the perception, either internally or externally.

The rebrand starts with how departments see themselves

The most important audience for the tax department’s rebrand isn’t the C-Suite. It’s the department itself.

That means tracking wins and building a formal business case for investment 鈥� grounded in hard ROI and cost savings, which the report identifies as the metrics that are most important to Finance and IT, the two functions that frequently share control of the tax technology budget.

It also means getting serious about leadership. The portion of tax departments with a designated person leading tax technology strategy jumped to 88%, from 51%, in a single year. However, a title only goes so far; and the report is clear 鈥� that role only works when backed by a team that believes it belongs at the decision-making table.

Finally, this rebranding means treating AI as an opportunity, not a threat. The majority of tax professionals have compressed their expectations for AI integration to 1鈥�2 years, from 3鈥�5 years, with 7% saying AI is already central to their workflow. Those departments still locked in cost-center mode are the least prepared for that shift 鈥� because cost centers don’t invest ahead of the curve.

The narrative changes when the mindset changes

No one is going to rebrand the tax department on its own, it has to come from within. Further, it has to be built through deliberate measurement, consistent communication, and a shift in how tax professionals think about our own work.

Your department is not a cost center. The work proves it, and the data backs it up. Now, you should act like you believe it.

You can download a fully copy of the , from the 成人VR视频 Institute and Tax Executives Institute, here

Key takeaways:

• • • Prompt engineering pays off 鈥� Tax professionals who master clear, contextualized AI instructions see immediate gains in output quality and speed.

    • AI doesn鈥檛 replace professional responsibility 鈥� Every output that carries your name requires your verification and your judgment.

    • Link learning to a real problem 鈥� The most effective way to build needed skills is to focus on your current workflow, not to chase every new tool as it emerges.

For tax professionals, technical excellence used to be enough. Know the code, understand the cases, apply the rules correctly 鈥� that was the job, and it was sufficient. It isn’t anymore. Not because the technical knowledge matters less, but because the professionals competing for the same work increasingly bring other talents to the table, such as the ability to do in an hour what used to take a day; to provide insights from data that would have taken a week to compile manually; and to deliver polished, well-reasoned analysis at a pace that wasn’t possible five years ago.

This rarified capability doesn’t come from intelligence or experience alone; rather, it comes from skills 鈥� specific, learnable, practical skills.

The data bears this out. Improving efficiency through technology has been the top strategic priority for firms for three consecutive years, with 44% of firm leaders citing it as their primary focus, according to the 成人VR视频 Institute鈥檚 . Indeed, 47% of tax professionals surveyed said investing in AI should now be a top priority 鈥� and yet, 18% of firms still use no automation at all.

This gap between intention and capability is real, and it sits squarely with the individual tax professional.

The skills most needed by today鈥檚 tax professionals

To help close this gap and improve tax professionals鈥� overall work value, there are several specific skills that demand attention, including:

Prompt engineering: The skill nobody takes seriously until they see what it does

The name doesn’t help 鈥� but set that aside, because the underlying skill is straightforward: giving your AI tools clear, precise, well-contextualized instructions that produce outputs that are worth using.

Most people start badly when approaching a blank AI screen. They type something vague, get something generic, and conclude the tool isn’t useful. That conclusion is wrong, because it was the instructions given, the prompt, that was the problem. Specify the entity type, jurisdiction, tax year, audience, and format. Then tell the tool what you need and why. The difference in output quality is not marginal.

Of course, it鈥檚 important to remember that AI will tell you things that are wrong with complete confidence. It will cite an amended provision, apply a rule from the wrong jurisdiction, or construct a plausible analysis on a flawed premise 鈥� all without flagging any of it. The professional responsibility to catch it remains entirely upon the user. That’s not a flaw in the tool; it’s a reminder that expertise isn’t being replaced here 鈥� it’s being put to better use.

Data literacy: The capability gap most tax professionals don’t know they have

Tax work is data work. Today, what has changed is the expectations around the volume and complexity that professionals are now required to handle, interpret, and present, often with fewer resources than a decade ago.

Advanced spreadsheet proficiency is the starting point, and the emphasis on advanced is deliberate. The features that most professionals have never explored are precisely the ones that separate those who spend three hours processing data from those who spend 20 minutes. The ability to build visual dashboards that communicate tax data clearly 鈥� effective tax rates, provision variances, deferred movements, and more 鈥� is increasingly an expectation in corporate environments rather than a differentiator. For those professionals who handle large datasets or complex scenario modeling, even a foundational understanding of represents a significant capability uplift.

The Tax Professionals Report found that 57% of firm leaders cited getting better use out of existing technology as their top investment priority 鈥� more than those planning to buy new systems. The problem, in other words, isn’t the tools; it鈥檚 having the skills and the understanding to use them.

Workflow automation: Reclaiming time from work that shouldn’t exist

Look at any tax workflow closely and you’ll find steps that are repetitive, rule-based, and time-consuming 鈥� not because they require a tax professional鈥檚 skilled judgment, but because nobody has stopped to ask whether these routine tasks could be done differently.

Again, the harder part of improving your skill set as a tax professional isn’t learning the tools; rather, it’s developing the habit of process analysis, a way of thinking that will allow you (among other things) to distinguish between steps that require genuine expertise and steps that are simply consuming time.

AI judgment: Knowing what to trust and what to verify

This is the skill that determines whether AI makes you more effective or creates problems you didn’t anticipate. This means validating outputs against primary sources before they reach a client. It means recognizing that AI reflects training data that may be outdated or jurisdiction-specific in ways that aren’t readily apparent in the output. And it means knowing when a task is too nuanced or too high stakes for AI to handle reliably.

Professional responsibility does not transfer to the tool itself. If an AI-generated analysis carries your name, it is your analysis.

Communicating and staying current

As routine tax compliance work becomes more automated, the premium on communication rises sharply. The Tax Professionals Report found that three-quarters of clients now strongly desire advisory services beyond tax preparation from their outside tax professional 鈥� yet most tax firms still derive their greatest profits from simple tax return preparation.

Those professionals who can close that gap are those who can translate technical work into clear, confident guidance that their clients can act on.

Going forward, the tools will keep changing. Identify the problem in your current workflow that costs the most time, find the skill that addresses it, and build from there. The professionals who will define the next decade will combine this deep technical knowledge with the ability to work faster, more clearly, and more adaptively than those who came before them. That combination is not yet common, but it鈥檚 also not out of reach.

For more on how tax professionals are navigating technological change, visit the or download the full 2025 State of Tax Professionals Report

Key takeaways:

• • • Your post-OBBBA forecasts should look different 鈥� If the tax department doesn’t own the OBBBA model, someone else will own the OBBBA story.

• • • Rely on your department鈥檚 inner strengths 鈥� It鈥檚 governance and analysis 鈥� not tools 鈥� that get you into the strategy room.

    • Factor in the conflict in the Middle East 鈥� The Iran war risk belongs in your tax model, not just in your CFO’s macro deck.

The One Big Beautiful Bill Act (OBBBA), signed into law in July 2025, enacted large business tax cuts, most notably by providing permanent full expensing of many forms of investment. Under the previous major corporate tax legislation, 2017鈥檚 Tax Cuts and Jobs Act (TCJA), bonus depreciation was scheduled for gradual phase-out following 2023. The OBBBA restored that expensing 100% retroactively for assets acquired from mid-January 2025 onwards.

The after-tax cost of new machinery, fleets, and equipment has effectively fallen by around 21%, designed to encourage immediate capital outlays by allowing businesses to write off these expenses in the year they are incurred rather than amortizing them over five years.

For corporate tax departments, that’s not a disclosure footnote 鈥� that’s your capital plan.

Capital-intensive corporations will see tax burdens reduced through permanent rate extensions, depreciation adjustments, and expansion of the state and local tax (SALT) deduction cap 鈥� but only if your models are built to capture the timing and location of investment, the mix of debt compared to equity, and where your organization books its next dollar of income.

Not surprisingly, most corporate tax departments aren’t there yet. They’re still recalculating last year, plus a few adjustments. That’s glorified compliance, not modeling.

A standout tax department doesn’t ask, What’s the OBBBA impact? Rather, it asks, Which version of OBBBA do we choose for this business? 鈥� and it has the models to back it up.

From spreadsheet heroics to controlled modeling

For many organizations, tax modeling still means creating a massive spreadsheet that only one director truly understands. The spreadsheet gets pulled out for budget season, rebuilt under pressure, and quietly retired until next year. That’s a single point of failure, not a process.

And after OBBBA, continuing that practice is dangerous. One wrong assumption on expensing or interest limitation can move cash tax by millions of dollars and blindside the Finance Department.

Here’s what disciplined modeling looks like in practice:

• • • Create a unified model 鈥� Build one integrated model that the whole team can use or accept that your department is choosing to fly blind.
    • Use the same assumptions 鈥� Standardize the levers that matter most (such as capex timing, financing mix, jurisdiction, and incentives) and make sure every scenario runs off the same assumptions.
    • Conduct modeling reviews 鈥� Treat major OBBBA-driven decisions (such as large capex, funding shifts, supply-chain redesign) as tax deals that must go through a modeling review before they’re greenlit.
    • Document your assumptions explicitly 鈥� Under permanent full expensing, the difference between a well-supported assumption and a poorly documented one isn’t just an audit risk, rather it’s a credibility problem with your CFO.

It鈥檚 also important to remember that in a post-OBBBA world, this level of disciplined modeling is not technology transformation 鈥� it鈥檚 basic survival.

Governance: Where leaders quietly win or loudly fail

The differentiator isn’t which corporate tax department has the fanciest tool 鈥� it’s which one has the cleanest governance. And the data is unambiguous: More than half (55%) of tax departments are still in the reactive phase of their technological development, stuck with five capex models circulating with five discount rates and the tax team arriving late to the planning meeting.

Those tax departments that are breaking out of that pattern share one trait: They put someone formally in charge. In the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report, a large portion (88%) of survey respondents said their company had appointed a person to lead the tax department’s technology strategy. That number jumped a whopping 37 percentage points, from 51%, from the previous year鈥檚 survey. That single structural move separates those departments with a governance model from those that simply hold a governance conversation every budget cycle and forget about it.

Clearly, this type of ownership drives results. Two-thirds of those surveyed agreed that their company’s investment in technology has enabled a shift from routine, reactive work to more strategic, proactive, higher-value work.

Under OBBBA, the kind of governance isn’t housekeeping. It’s how you get invited into strategy discussions instead of having to clean up after things go awry.

Why your OBBBA win may not feel like a win

On paper, the tax changes embedded in the OBBBA look generous. In practice, your effective tax benefit is colliding with something you don’t control.

When the war on Iran began, all shipping through the Strait of Hormuz was effectively halted, removing roughly one-fifth of the world’s oil and gas supply from the market. Fuel prices throughout the world spiked and are likely to remain elevated as long as conflict persists.

With oil prices hovering around $100 a barrel, there are will wipe out the benefits of higher tax refunds this year for most Americans. If those benefits, arising from Trump’s 2025 tax cuts, are erased for the average American, only the top 30% of taxpayers will still seeing a net gain.

For corporate planning purposes, the parallel dynamic is real: The topline OBBBA benefit is being eroded by higher fuel, freight, and financing costs across the business and its supply chain.

Inflationary pressures are being driven by higher energy prices tied to the Iran war, and the conflict’s impact on a wide range of goods and services is likely to last for months 鈥� with experts saying even a ceasefire is unlikely to immediately ease global energy shortages.

A serious corporate tax department doesn’t handwave these concerns away. It takes three actions:

1. 1. 1. Run a war-extended scenario 鈥� The scenario should show exactly how sustained higher energy costs and borrowing rates change the payoff from accelerated expensing and leverage 鈥� with specific numbers, not just directional commentary.
      2. Share your forecasts internally 鈥� Put your monthly or quarterly cash-tax forecasts on the table for Finance to see, so that it can manage liquidity rather than hope the annual plan holds.
      3. Force the hard conversation 鈥� Ask the tough question: At today’s rates and fuel costs, the after-tax return on this project is X. Are we still in? That question should come from the tax team now, not from the finance team six months later.

Clearly, the daily fluctuations in oil prices matter less than monthly and quarterly averages 鈥� and volatility will likely remain elevated given the absence of a clear timeline for the end of the war. That’s exactly the kind of sustained uncertainty that belongs front and center in your scenario set, not in a footnote.

The bottom line

The OBBBA gives corporate tax departments a genuine opportunity to move from being simply a compliance function to becoming more of a strategic advisor. Permanent full expensing, richer cost recovery, and more flexible interest rules can create real levers to add value, but only for those organizations that model them rigorously, govern them cleanly, and stress-test them against the macro environment their business actually faces today.

Indeed, the Iran war is a live test of that readiness. The corporate tax departments that show up with modeled scenarios, cash-tax forecasts, and a clear point of view on after-tax returns will earn a seat at the strategy table. The ones that show up with caveats will be asked to leave it.

You can download a full copy of the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report here

Key takeaways:

• • • Country-by-country reporting will only increase in complexity 鈥� Australia’s enhanced Country-by-country reporting (CbCR) requirements 鈥� reconciling taxes accrued against taxes credited 鈥� are a preview of where other high-scrutiny jurisdictions are heading, and companies need to build that explanatory analysis capability now, systematically, rather than scrambling later.

    • There has to be a shared narrative from corporate teams 鈥� The EU鈥檚 public CbCR is a reputational event, not just a filing. So that means tax, communications, and investor relations teams need a shared narrative before the data goes public 鈥� inconsistencies create exposure you do not want to manage reactively.

    • Rethink your filing jurisdiction in light of changes 鈥� If EU filing jurisdiction was chosen at initial implementation and never revisited, look again. Guidance has matured, and a more efficient or better-suited option may now be available.

WASHINGTON, DC 鈥� Among the many pressing topics discussed in detail at the recent , country-by-country reporting (CbCR) and its ability to reshape the corporate tax industry, certainly had its place. Between escalating local jurisdiction requirements, the , and for deeper explanatory disclosures, CbCR has quietly evolved from a transfer pricing filing obligation into something far more strategically consequential.

The floor is just the floor

The creation of the by the Organisation for Economic Co-operation and Development (OECD) was intended as a minimum standard for countries. And now jurisdictions are increasingly layering additional requirements on top of the OECD鈥檚 basic template, resulting in a widening gap between the standard requirements and what tax authorities actually want.

Currently, Australia is the most pointed example. Australian tax authorities are now requiring multinational groups to go beyond the standard CbCR data fields and provide explanatory narratives that reconcile taxes accrued against taxes actually credited. This requires corporate tax departments to bridge the gap between financial statement accruals and their organizations鈥� cash tax positions in a way that is coherent, defensible, and consistent with positions taken elsewhere.

At the TEI event, panelists explained that for tax departments this will carry complex timing differences, deferred tax positions, or significant jurisdictional mismatches between booked and cash taxes. Indeed, this additional layer of scrutiny will need dedicated attention.

The broader signal matters: Australia will not be the last jurisdiction to move in this direction. So that means that tax departments should treat Australia’s approach as a leading indicator of where other high-scrutiny jurisdictions could be heading. Building the capability to produce this kind of explanatory analysis systematically 鈥� rather than scrambling jurisdiction by jurisdiction 鈥� would be the smarter long-term investment for corporate tax teams.

Public CbCR in the EU: The transparency ratchet has turned

For US-based multinationals with significant European operations, the EU’s public CbCR directive has fundamentally changed the calculus. Unlike the confidential tax authority filings most corporate tax departments are accustomed to, the EU鈥檚 public CbCR rules put organizations鈥� jurisdictional profit and tax data into the public domain, making it visible to investors, journalists, civil society groups, and organizations鈥� employees and customers.

The EU framework specifies which entities trigger the reporting obligation and which entity within the group is responsible for making the public filing. That scoping analysis is not always straightforward for complex multinational structures and getting it wrong could present both reputational and legal risk.

Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data.

For US-headquartered groups, the implications extend well beyond Europe. Public CbCR data is now being read alongside US disclosures, reporting on ESG activities, and public narratives about tax governance. Inconsistencies, including those technically explainable, could create unwanted noise about the company. This is clearly another reason why the tax function should partner across the business 鈥� in this case with the communications team 鈥� to make they both are aligned to tell the CbCR story instead of being caught off guard by a journalist or an investor during an earnings call.

Questions that US multinationals should be asking

Fortunately, US multinationals with multiple EU subsidiaries are not required to file public CbCR reports in every EU member state in which they have a presence. Instead, under the EU framework, a qualifying ultimate parent or standalone undertaking can satisfy the public disclosure requirement through a single filing in one EU member state, provided the relevant conditions are met. Germany and the Netherlands have emerged as two of the more popular choices for this consolidated filing approach, given their well-developed regulatory frameworks and the depth of available guidance on what compliant disclosure looks like in practice.

The strategic implication is meaningful. Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data. Corporate tax departments that defaulted to a filing jurisdiction early in the EU implementation process should take a fresh look. Regulatory guidance has matured significantly, and there may be a more efficient or better-suited path available than the one originally chosen.

The uncomfortable divergence

There is a notable irony in the current environment. Domestically, the IRS and U.S. Treasury’s 2025-2026 Priority Guidance Plan reflects an explicit focus on deregulation and burden reduction, detailing dozens of projects aimed at reducing compliance costs for US businesses. Meanwhile, the international compliance environment has moved in the opposite direction, adding disclosure layers, explanatory requirements, and public transparency obligations that many US businesses cannot avoid simply because they are headquartered in the United States.

This divergence has a direct implication for how tax departments allocate resources and make the internal case for investment in international compliance infrastructure. The burden internationally is not going down 鈥� indeed, it is intensifying 鈥� and that argument is now backed by concrete examples rather than projections.

3 things worth doing now

There are several actions that corporate tax teams should consider, including:

Audit CbCR data quality with Australia’s enhanced requirements in mind 鈥� If you cannot readily reconcile taxes accrued to taxes credited at the jurisdictional level, that gap needs to be closed before it becomes an authority inquiry.

Revisit EU filing jurisdiction strategy 鈥� If your jurisdictional decision was made at the time of initial implementation and has not been reviewed since, it is worth a fresh look before the next reporting cycle.

Develop an internal narrative around public CbCR data before it circulates externally 鈥� Your company鈥檚 tax story should not be a surprise to the corporate teams involved in communications, investor relations, or ESG 鈥� and in today鈥檚 world, assuming such news stays quiet is no longer a safe assumption.

While CbCR started as a tool for tax authorities, it today has become something more visible, more public, and more consequential than that 鈥� and that trajectory is not reversing any time soon.

You can download a full copy of the 成人VR视频 Institute鈥檚

Key takeaways:

• • • Only IEEPA鈥慴ased tariffs are up for refund 鈥� Refunds will flow electronically to importers of record through ACE, the government鈥檚 digital import/export system, but only once CBP鈥檚 process is finalized.

    • Liquidation and protest timelines are now critical 鈥� An organization鈥檚 tax concepts that directly influence which entries are eligible and how long companies have to protect claims.

    • Tax functions must quickly coordinate with other corporate functions 鈥� In-house tax teams need to coordinate with their organization鈥檚 trade, procurement, and accounting functions to gather data, assert entitlement, and get the financial reporting right on any tariff refunds.

WASHINGTON, DC 鈥� When the United States Supreme Court issued its much-anticipated ruling on President Donald J. Trump鈥檚 authority to impose mass tariffs under the International Emergency Economic Powers Act (IEEPA) in February it set the stage for what it to come.

The Court ruled the president did not have authority under IEEPA to impose the tariffs that generated an estimated $163 billion of revenue in 2025. In response, the Court of International Trade (CIT) issued a ruling in requiring the U.S. Customs and Border Protection (CBP) to issue refunds on IEEPA duties for entries that have not gone final. That order, however, is currently suspended while CBP designs the refund process and the government considers an appeal.

At听the recent , tax experts discussed what this ruling means for corporate tax departments, outline what is and isn鈥檛 a consideration for refunds and the steps necessary to apply for refunds.

As panelists explained, the key issue for tax departments is that only IEEPA tariffs are in scope for refund 鈥� many other tariffs remain firmly in place. For example, on steel, aluminum, and copper; Section 301 tariffs on certain Chinese-origin goods; and new of 10% to 15% on most imports still apply and will continue to shape effective duty rates and supply chain costs.

So, which entities can actually get their money back?

Legally, CBP will send refunds only to the importer of record, and only electronically through the government鈥檚 digital import/export system, known as the Automated Commercial Environment (ACE) system. That means every potential claimant needs an with current bank information on file. And creating an account or updating it can be a lengthy process, especially inside a large organization.

If a business was not the importer of record but had tariffs contractually passed through to it 鈥� for example, by explicit tariff clauses, amended purchase orders, or separate line items on invoices 鈥� they may still have a commercial basis to recover their share from the importer. In practice, that means corporate tax teams should sit down with both the organization鈥檚 procurement experts and its largest suppliers to identify tariff鈥憇haring arrangements and understand what actions those importers are planning to take.

Why liquidation suddenly matters to tax leaders

As said, the Atmus ruling is limited to entries that are not final, which hinges on the . CBP typically has one year to review an entry and liquidate it (often around 314 days for formal entries) with some informal entries liquidating much sooner.

Once an entry liquidates, the 180鈥慸ay protest clock starts. Within that window, the importer of record can challenge CBP鈥檚 decision, and those protested entries may remain in play for IEEPA refunds. There is also a 90鈥慸ay window in which CBP can reliquidate on its own initiative, raising questions about whether final should be read as 90 days or 180 days 鈥� clearly, an issue that will matter a lot if your company is near those deadlines.

Data, controversy risk & financial reporting

The role of in-house tax departments in the process of getting refunds requires, for starters, giving departments access to entry鈥憀evel data showing which imports bore IEEPA tariffs between February 1, 2025, and February 28, 2026. If a business does not already have robust trade reporting, the first step is to confirm whether the business has made payments to CBP; and, if so, to work with the company鈥檚 supply chain or trade compliance teams to access ACE and run detailed entry reports for that period.

Summary entries and heavily aggregated data will be a challenge because CBP has indicated that refund claims will require a declaration in the ACE system that lists specific entries and associated IEEPA duties. Expect controversy pressure: As claims scale up, CBP resources and the courts could see backlogs. If that becomes the case, tax teams should be prepared for protests, documentation requests, and potential litigation over entitlement and timing.

On the financial reporting side, whether and when to recognize a refund depends on the strength of the legal claim and the status of the proceedings. If tariffs were listed as expenses as they were incurred, successful refunds may give rise to income recognition. In cases in which tariffs were capitalized into fixed assets, however, the accounting analysis becomes more nuanced and may implicate asset basis, depreciation, and potentially transfer pricing positions.

Coordination between an organization鈥檚 financial reporting, tax accounting, and transfer pricing specialists is critical in order that customs values, income tax treatment, and any refund鈥憆elated credits remain consistent.

Action items for corporate tax departments

Corporate tax teams do not need to become customs experts overnight, but they do need to lead a coordinated response. Practically, that means they should:

• • • confirm whether their company was an importer of record and, if so, ensure ACE access and banking information are in place now, not after CBP turns the refund system on.
    • map which entries included IEEPA tariffs, identify which are non鈥憀iquidated or still within the 180鈥慸ay protest window, and file protests where appropriate to protect the company鈥檚 rights.
    • inventory all tariff鈥憇haring arrangements with suppliers, assess contractual entitlement to pass鈥憈hrough refunds, and align with procurement and legal teams on a consistent recovery approach.
    • work with accounting to determine the financial statement treatment of potential refunds, including whether and when to recognize contingent assets or income and any knock鈥憃n effects for transfer pricing and valuation.

If tax departments wait for complete certainty from the courts before acting, many entries may go final and fall out of scope. The opportunity for tariff refunds will favor companies that are data鈥憆eady, cross鈥慺unctionally aligned, and willing to move under time pressure.

You can find out more about the changing tariff situation here