The world if going Global… and so am I. This blog post is being written from the Qantas Club at LAX. I am headed to Australia for two weeks of speaking. Four sessions for IBM Cognos Finance Forum, three CFO luncheons for Agility Consulting and it all starts with a May 4th appearance at the Institute of Charted Accountants — Australia on May 4th. All I can say crossing the tarmac at LAX is the A380 is the biggest plane I have ever seen (or will likely ever fly on). It is a cross between a bus and a super tanker. Look for more thoughts as I track how finance is getting smarter around the world.

I will report in again from the land down under. Text me your questions (ATT lets them come into my cell phone for free).

If you have some thoughts about the Affordable Care Act (ACA)– specifically, on what are being referred to as the “shared responsibility provisions,” as well as on the 90-day limitation for waiting periods – the IRS is listening. Notice 2011-36, which was posted today on IRS.gov, is requesting the public’s input, as both Treasury and the IRS develop guidance that will help employers comply with these provisions.

Under the Affordable Care Act, starting in 2014, employers with 50 or more full-time employees that do not offer affordable health coverage to their full-time employees may be required to make a shared responsibility payment. More specifically, under § 4980H of the ACA, an employer may be liable for an “assessable payment” if at least one of its full-time employees is certified as having enrolled in health insurance through one the state exchanges that are to be developed. As the Notice states, “The definition of full-time employee is key in determining whether and, if so, to what extent, an employer may incur § 4980H(a) liability or § 4980H(b) liability,” as the assessments will vary with the number of full-time employees. So, the IRS is looking for comments on possible approaches employers could use to determine just which employees should be considered full-time.

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Ask a veteran of a Big 4 firm or any mid-sized to large consulting firm (with strong corporate finance services) what one of their most reliable sources of revenue is and, chances are, you’ll hear a blast from the past: Sarbanes-Oxley compliance.

SOX compliance engagements are not as big and disruptive as they once were, but they remain a reliable source of income for consulting firms because companies continue to wrestle with internal controls management and monitoring.

Part of the problem is that, in many companies, the internal audit function’s hand-off of compliance and controls responsibilities to operations was at least partially interrupted by the economic crisis. Many organizations whacked costs (and people) from back-office functions, including internal audit, so these functions clicked out of value-add mode and into “do more with less mode.” In practice, that really meant doing the same with less.

Size also matters. While many smaller companies avoided the exhaustive and confusing SOX compliance exercises that larger companies experienced from 2002 through 2004, they are beginning to realize that better controls translate to greater business agility – a must-have capability in a highly volatile economic period.

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