HUD compliance

This article is part of a series detailing meaningful proposed tax law changes that could have far reaching implications to all types of businesses.

The debate and negotiations over tax reform are taking shape in the United States Congress. The United States Senate is reviewing the ‘One Big Beautiful Bill Act’ (OBBBA) passed by the US House of Representatives in late May. The House-passed legislation contains meaningful tax reforms with potentially significant impact to businesses and individuals.

Bonus depreciation and Section 179 expensing

The OBBBA also proposes significant changes to bonus depreciation and Section 179 expensing.

Bonus depreciation: The current 40% bonus depreciation for 2025 is proposed to return to 100% for qualified assets placed in service after January 19, 2025, and before January 1, 2030. This allows businesses to fully deduct the cost of eligible assets upfront.

Section 179 expensing: The maximum Section 179 deduction is proposed to increase from $1,250,000 to $2.5 million, with the phase-out threshold rising from $3,130,000 to $4 million.

Key differences: Section 179 cannot create a loss, while bonus depreciation can. Most states do not follow bonus depreciation rules, but some allow Section 179.

Qualified Business Income (QBI) deduction extension and enhancement

The OBBBA extends the existing law that allows a deduction against business income for qualifying flow-through businesses (non-C-corporation entities).

Deduction enhancement: The deduction for QBI will increase from 20% under current law to 23% for tax year beginning after December 31, 2025.

Permanent extension: The deduction for QBI will be made permanent

Threshold limit and inflation adjustment: The taxable-income threshold (currently $197,300 for singles / $394,600 for joint filers in 2025) is increased for inflation, maintaining higher eligibility before limitations begin.

This provision aims to promote economic growth and incentivize the development of new businesses by reducing the income tax costs to business owners of flowthrough entities.

Business interest deductions (Section 163(j))

The OBBBA aims to revise how deductible interest expenses are calculated under Section §163(j).

Adjusted Taxable Income (ATI) calculation: Pre-2022, EBITDA (earnings before interest, tax, depreciation and amortization) was used, allowing higher deductions. From 2022–2024, EBIT became the basis, reducing deductible interest for many companies. The House bill will temporarily restore EBITDA as the basis for tax years 2025 through 2029, which would increase interest deductibility for capital-intensive businesses.

Deduction limit: The 30% of Adjusted Taxable Income deduction limit remains unchanged.

Small business exemption: Currently, businesses with average gross receipts of $30 million or less over the previous three years are exempt from the interest expense limitation. The OBBBA proposes to extend the lookback period to five years and add a new $80 million threshold for manufacturing businesses, with both thresholds subject to inflation adjustments. This could qualify more small and mid-size manufacturers for exemption and provide stability for businesses with fluctuating revenue.

Carryforward rules: Disallowed interest can still be carried forward indefinitely, with rules varying by entity type (C-Corp, Partnership, S-Corp).

This table summarizes the changes:

These changes could offer substantial tax relief, especially for businesses with significant debt financing or capital investments.

The bill is still in committee but has a target enactment date of July 4, 2025, making it crucial for planning. BerryDunn’s tax and compliance team has a deep understanding of the proposed tax reforms and can help you and your business plan for these changes to maximize the opportunities and minimize the costs.

In our work with clients on financial stewardship and internal controls, we often see organizations—especially small businesses, nonprofits, and governmental entities—struggling to balance purchasing flexibility with risk management. Credit cards, purchase cards (p-cards), and debit cards each offer convenience for small-dollar purchases, but also carry varying levels of risk. Implementing strong internal controls is essential to prevent fraud, misuse, and compliance violations. 

Below are best practices tailored to each payment method, with a focus on safeguarding your organization’s assets and ensuring accountability. Establishing clear policies and effective internal controls for each card type should be a top consideration.   

Credit cards: Widely used, but not without risk 

Credit cards are a common tool for operational purchases. However, without proper oversight, they can become a source of fraud and abuse.  

• Monthly independent reviews: Assign a finance team member not involved in card use to review all transactions monthly. This segregation of duties is a cornerstone of effective internal control. 

• Card issuance protocols: Establish a formal approval process for issuing cards, including a credit limit based on job function and purchasing needs. 

• Policy clarity: Define allowable and prohibited uses. For example, prohibit use for grant-funded or capital expenditures unless pre-approved, as these often require additional documentation and controls. 

• Receipt compliance: Require timely submission of receipts and outline consequences for non-compliance (e.g., suspension of card privileges). 

• Employee acknowledgment: Have employees sign a credit card policy agreement annually to reinforce accountability. 

P-cards cards: Flexible and controllable 

P-cards offer more granular control than traditional credit cards, making them a preferred option for many organizations.  

• Vendor restrictions: Limit card use to a pre-approved vendor list to reduce the risk of unauthorized purchases. 

• Role-based limits: Customize spending limits by department or role to align with operational needs. 

• Pre-payment review: Require review of all receipts and transaction logs before paying the monthly bill. 

• Documentation enforcement: Make receipt submission mandatory and enforce consequences for missing documentation. 

• Audit trail: Maintain a centralized log of all p-card activity for audit readiness and transparency. 

Debit cards: High risk, use with caution 

While debit cards provide immediate access to funds, they expose organizations to greater risk due to limited fraud protection and direct access to bank accounts. Debit card use should have robust internal controls and monitoring.  

• Real-time monitoring: Use online banking tools to monitor transactions daily. Assign this task to someone without card access. 

• Transaction limits: Set daily spending and withdrawal caps to minimize potential losses. 

• Bank alerts: Enable transaction alerts for real-time oversight. 

• Bank protections: Choose a bank that offers strong fraud protection and insurance coverage for business accounts. 

• Incident response plan: Develop and test a response plan for potential breaches, including steps for reporting, containment, and recovery. 

Note: Due to the inherent risks, debit cards are generally not recommended for business use unless absolutely necessary and tightly controlled. 

Special considerations for nonprofits and governmental entities 

For nonprofits and governmental organizations, internal controls are not just best practices—they are often compliance requirements. Misuse of funds, especially grant money, can lead to serious consequences, including loss of funding or legal action. 

Our recommendations 

• Avoid debit cards: Stick to credit or purchase cards with stronger controls. 

• Grant compliance: Ensure all purchases made with grant funds are allowable and properly documented. 

• Policy integration: Align card policies with your organization’s broader financial and grant management policies. 

Final thoughts 

Choosing the right purchasing method is about more than convenience—it’s about protecting your organization’s financial integrity. We recommend reviewing your current practices and updating your policies to reflect these best practices. If you need help assessing your internal controls or designing a card policy tailored to your organization, BerryDunn can help. Our specialized nonprofit and governmental teams work with organizations throughout New England and beyond. We understand and embrace the unique challenges faced by these entities—and recognize the vital importance of putting the mission first. Learn more about our team and services.   

Anyone involved in international operations, finance, or compliance should pay attention to first sale declarations—here’s why.  

This article is part of a series to help businesses navigate trade strategies amidst tariff changes. Next up: Duty drawbacks.

In the complex world of international trade, businesses are constantly seeking ways to optimize their supply chains and reduce costs. One often-overlooked strategy that can yield significant savings is the use of first sale declarations. This customs valuation method allows importers to declare the transaction value of goods based on the price paid in the first sale of a multi-tiered supply chain—typically the sale between the manufacturer and a middleman—rather than the final sale to the importer. When used correctly, this approach can substantially lower the declared customs value, resulting in reduced import duties and taxes. 

Understanding the first sale rule 

The first sale rule is rooted in US Customs and Border Protection (CBP) regulations and has been upheld through various rulings and court decisions. It is particularly relevant in scenarios where goods are manufactured overseas and sold through intermediaries before reaching the final buyer in the United States. For example, if a US importer purchases goods from a trading company that, in turn, buys from a manufacturer, the importer may be eligible to declare the customs value based on the manufacturer’s price—provided certain conditions are met. 

 This can be a game-changer for companies importing high-volume or high-duty goods. Even a small reduction in the declared value can translate into significant cost savings over time. However, the benefits of the first sale rule come with a caveat: strict compliance requirements. 

Requirements for first sale declarations 

To leverage the first sale rule, importers must demonstrate that the first sale was a bona fide, arm’s length transaction. This means the sale must be legitimate, conducted in good faith, and not influenced by related-party interests. Additionally, the goods must be clearly destined for export to the United States at the time of the first sale. 

Documentation is critical. Importers must maintain a robust paper trail that includes: 

• Contracts and purchase orders between all parties in the supply chain 
• Proof of payment and invoices 
• Shipping documents that trace the movement of goods from the manufacturer to the final destination 
• Evidence that the goods were destined for the US at the time of the first sale 

CBP may scrutinize these documents during audits or reviews, so accuracy and completeness are essential. Failure to meet the documentation requirements can result in penalties, retroactive duty assessments, and loss of eligibility for the first sale rule. 

How we can support you 

Navigating the intricacies of first sale declarations can be daunting, especially for businesses without dedicated customs compliance teams. That’s where we come in. Our experts can provide guidance on whether the first sale rule is a viable option for your operations. 

We can advise and coordinate end-to-end support to help you understand your options, identify opportunities, and help ensure compliance.

Our goal is to help you unlock the full potential of this powerful cost-saving strategy while minimizing risk and ensuring compliance with all applicable regulations. 

Let’s talk strategy 

In today’s dynamic trade environment, where tariffs and regulatory policies can shift rapidly, proactive planning is more important than ever. Don’t let uncertainty erode your margins. By exploring options like first sale declarations, you can gain a competitive edge and improve your bottom line. 

If you’re interested in learning more about how this strategy could benefit your business, we invite you to reach out. Let’s discuss your unique situation and develop a tailored approach that turns complexity into opportunity. 

Read the other articles in our series about tariffs.  

This article is adapted from the podcast, Let's talk parks with BerryDunn. Listen to the full episode.

Chris Bass never imagined that a single career decision would lead him to where he is today. Nearly 17 years ago, he stepped into the world of parks and recreation in Columbus, Georgia, eager to make a difference in his community. He quickly realized the depth of the field—the impact parks have on families, the way well-planned recreational spaces can shape neighborhoods, and the importance of strong leadership in bringing it all together. 

His journey took him to Douglasville (Georgia) Parks and Recreation, where a new challenge awaited. The department was preparing to pursue accreditation from the Commission for Accreditation of Parks and Recreation Agencies (CAPRA), a rigorous process that would validate its commitment to excellence. At first, Bass was overwhelmed. Accreditation wasn’t just a checklist—it was about meeting nationally recognized standards, proving the department’s value, and ensuring sustainable success. But instead of shying away, he leaned in. He built a team, rallied support, and worked tirelessly to strengthen the department. 

That dedication paid off. As the years passed, Bass became a respected leader in the field. His expertise and relentless commitment to quality earned him a new role—as chair of CAPRA. Recently, he sat down with BerryDunn’s Lakita Frazier on the Let’s Talk Parks podcast to discuss his perspective on CAPRA accreditation and lessons he’s learned along the way.  

Why CAPRA accreditation matters to parks and recreation agencies 

Bass describes CAPRA accreditation as a “stamp of approval,” but it is much more than that. It is the foundation of a well-run parks and recreation department, offering proof that an agency is operating at the highest standards. In a competitive municipal environment where funding is tight and priorities shift, accreditation gives departments the credibility they need to advocate for resources and drive innovation. 

But accreditation is not just about securing funds. It strengthens the trust between parks departments and the communities they serve. It ensures consistency in operations, improves long-term planning, and helps agencies build a resilient workforce that can navigate future challenges. 

Overcoming hurdles to CAPRA accreditation 

Bass knows the path to accreditation can seem daunting. Many departments hesitate, fearing they will not meet the required benchmarks or that sustaining accreditation over time will be too difficult. But take a different view. Bass urges agencies to start the journey, no matter how uncertain they feel. The key, he says, is to recognize the strengths within the team. Every department has passionate staff members who bring knowledge and expertise. By working together, agencies can not only achieve accreditation but also build a stronger, more effective workforce. 

The role of consultants in the CAPRA accreditation process 

Throughout his career, Bass has seen how consultants can play a valuable role in accreditation efforts. He recalls the business plan that BerryDunn helped develop for a new recreation center and the strategic planning that continues today. He believes consultants should align their work with CAPRA standards, ensuring their plans genuinely support accreditation goals. However, he offers a word of caution—departments should take ownership of their narratives. Accreditation is about telling their story, showcasing their unique contributions, and demonstrating their commitment to excellence. That cannot be outsourced. 

Advice for future leaders 

Finally, Bass has some useful advice for professionals looking to grow in the parks and recreation field. He encourages them to step beyond their comfort zones, explore different roles within the industry, and connect with diverse professionals who can broaden their perspectives. Growth, he says, comes from challenging oneself, embracing new experiences, and staying open to learning. 

BerryDunn's Parks, Recreation, and Libraries team works with clients across the country to improve operations, drive innovation, identify improvements to services based on community need, and elevate your brand and image―all from the perspective of our team’s combined 100 years of hands-on experience. Contact us to learn more about our team and services. 

In the wake of significant federal policy changes, nonprofit organizations that rely on federal grants and programs face new uncertainties. Since January 20, 2025, numerous Executive Orders (EOs) have been signed, aimed at restructuring the size and oversight of the federal government. While these policy shifts impact a wide range of sectors, nonprofit organizations—especially those providing social services—must prepare for potential disruptions to their funding. 

Many of these EOs seek to delay, modify, or eliminate programs that nonprofits depend on. Notably, the dissolution of Diversity, Equity, and Inclusion (DEI) support programs has created instability for social-service funding sources, including grants through US Department of Housing and Urban Development (HUD). As legal challenges to these policy changes continue, the fate of many funding programs remains uncertain. 

In times of transition, preparation is key. Nonprofit leaders must assess the risks and strategically position their organizations to adapt to changing funding landscapes. This article outlines key steps to help your organization proactively evaluate funding vulnerabilities, mitigate risks, and plan for sustainable operations. 

Conducting a strategic risk assessment 

A structured risk assessment allows nonprofit leaders to gain a clear understanding of their financial vulnerabilities and take action to protect key programs. We recommend a multi-step approach, starting with financial planning and gradually incorporating additional layers of strategic analysis. 

Step 1: Assess current funding sources 

Begin by taking an inventory of all current and long-term revenue sources. Identify which grants and funding streams come from federal programs, and classify them based on stability and potential risk. 

Step 2: Identify at-risk programs 

As policies shift, determine which programs may be most affected by government changes. Some grant administrators may face staffing reductions, making it difficult to access funding information. Networking with industry peers can provide insights into evolving federal priorities. 

Step 3: Track policy and budget developments 

Assign a staff member or team to monitor federal EOs, legislative actions, and budgetary adjustments that could impact funding availability. Staying informed about policy shifts will help nonprofit leaders anticipate changes and respond proactively. 

Step 4: Create a risk matrix 

A risk matrix can help nonprofits classify funding sources based on likelihood of disruption: 

• High Risk: Programs likely to be defunded, canceled, or eliminated. 
• Medium Risk: Funding programs that have not been directly targeted but could be affected by broader budget cuts. 
• Low Risk: Confirmed funding sources that are unlikely to change. 

By sorting funding sources into risk categories, leadership teams can prioritize critical discussions with stakeholders and the board. 

Strengthening financial strategies 

Uncertainty surrounding federal funding can lead to operational difficulties, but proactive financial planning will allow nonprofits to adapt the changing environment. BerryDunn’s nonprofit consulting team specializes in change management, helping organizations navigate complex funding and policy landscapes. 

Additionally, our expert team empowers nonprofits to optimize their reimbursement strategies and enhance budget resilience. Strategic financial planning ensures organizations maximize their resources while minimizing risk exposure. 

Take action today 

Preparation is the key to nonprofit sustainability in a shifting policy environment. To help organizations streamline their risk assessment process, BerryDunn has developed free workbook templates that simplify financial analysis. 

Download our eBook and financial risk assessment templates today to take the next step toward stability. 

Federal policy changes don’t have to derail your organization’s mission. With the right tools, nonprofits can build resilience and continue making a meaningful impact.