Q3 Is Closed. The Next 90 Days Will Decide Your Year-End Provision.
Build year-end tax accounting from provision-specific enacted law, effective dates and reporting-entity requirements. Domestic R&E, NCTI, Pillar Two and ASU 2023-09 do not share one rule or date.
Editorial source review — November 1, 2026. This machine-generated article has been reviewed, but is not certified accurate. Source-backed corrections are incorporated where established. Other legal, survey and product claims may remain unverified; check applicable primary authorities before relying on a deadline or tax position.
Findings in the original version: the article aggregates R&E, section 250 and disclosure changes, but they do not share a single effective date or accounting effect.
Quarter-end review requires separate analysis of law, effective date, reporting framework and the company's actual positions. A quarterly alert is a starting point, not a complete list of required accounting entries.
Domestic R&E and international inclusions
Section 174A generally permits a deduction for qualifying domestic R&E paid or incurred in tax years beginning after December 31, 2024, with elections and transition rules. Foreign research remains separate. Immediate domestic deductibility does not automatically generate a larger DTA; compare the actual book carrying amount and tax basis.
Section 951A governs net CFC tested income; section 951B is a different rule for foreign-controlled US shareholders. For tax years beginning after December 31, 2025, the eligible section 250 deduction on net CFC tested income and its related section 78 amount is 40%, subject to limitations. A 12.6% pre-credit illustration is not every entity's actual effective rate.
Pillar Two accounting and safe harbours
Do not infer safe-harbour eligibility from being within two or three percentage points of 15%. Apply the actual tests, elections, fiscal-year rules and local law. Separate GloBE deferred-tax inputs from financial-statement recognition of future top-up taxes. The FASB staff's illustrated AMT analysis does not create new DTAs or DTLs for estimated future GloBE effects.
Disclosure effective dates and threshold
ASU 2023-09 applies to annual periods beginning after December 15, 2024 for public business entities and after December 15, 2025 for other entities. For the applicable public-entity rate reconciliation, use specified categories and the further-disaggregation threshold based on 5% of pretax income or loss multiplied by the applicable statutory income-tax rate—not 5% of actual tax expense. Income taxes paid disclosure is separate.
Complete the period review
Check enactments through the actual reporting date, document elections and uncertainty, and assess realisability using company-specific forecasts. A publication with a September 18 cutoff cannot establish complete September 30 coverage.
Sources
- 26 USC 174A and effective-date notes
- 26 USC 250
- 26 USC 951B
- FASB ASU 2023-09
- FASB February 1, 2023 staff technical-inquiry discussion