Fresh Start Reporting Can Save Your Business

Scrubbed

Scrubbed

Fresh Start Reporting Can Save Your Business

Global challenges like the after-effects of the pandemic, high inflation, rising interest rates, the looming threat of recession, supply chain constraints, the emerging monkeypox virus, and the war in Ukraine continue to test businesses across many industries. The number of companies facing financial distress has increased, forcing some to file bankruptcy or reorganize. Though the bankruptcy process involves distributing the remaining assets to the failing business’s creditors, it also allows some organizations to make a fresh start by reorganizing to be more economically feasible. 



There are six different types of bankruptcy filings under the Bankruptcy Code, and the most common for US businesses is Chapter 11, which allows companies to reorganize. If your business is considering a bankruptcy filing, it’s important to understand the benefits, qualifications, and challenges of fresh-start reporting.



Check out our Corporate Finance Advisory page and see how Scrubbed can help you!



What Fresh-start Reporting Allows


To reorganize under Chapter 11, a business must prepare a reorganization plan that is subject to court approval. Once that plan is approved by the court and the company has emerged from bankruptcy, the business can begin to apply fresh-start reporting if it meets the associated requirements under ASC 852 – Reorganizations (outlined below). 



Under fresh-start reporting, the business starts anew, with its balance sheet items adjusted based on newly determined fair values. The business is considered separate from its predecessor company (the organization that has undergone a default) and now has clean financials and possibly a stepped-up value of assets. Fresh-start reporting provides an opportunity for most companies, as it denotes that the emerging entity is more robust and has a promising future.



The Criteria for Fresh-start Reporting


As stated in the American Institute of Certified Public Accountants Statement of Position (SOP) 90-7, Financial Reporting Entities under Bankruptcy Code, a reporting entity must apply fresh-start reporting after emerging from bankruptcy if it qualifies on both of the following criteria:

  • Reorganization value test. The reorganization value of the emerging entity immediately before the date of confirmation (when the court approves the reorganization plan) must be less than the total of all post-petition liabilities (the liabilities incurred after the bankruptcy is filed) and allowed claims. This test aims to prevent companies that are solvent and able to finance their operations from applying fresh-start reporting.
  • Loss of control test. The holders of existing voting shares immediately before confirmation must receive less than 50% of the voting shares of the emerging entity. This test prevents companies from filing a bankruptcy petition to adopt fresh-start reporting and write-up value of assets.


Also read:  The Rise of Digital Assets in Business



A Closer Look at the Reorganization Value Test


The reorganization value is the approximate fair value of the company’s assets without considering its liabilities. Though it may sound straightforward, obtaining the reorganization value requires extensive arms-length negotiations among various parties. This process is vital, as it serves as the basis for determining the value received by the business’s creditors and equity holders.



The reorganization value is commonly determined as a range rather than a single-point estimate; however, an entity will choose a value within a range. Companies typically use the discounted cash flow (DCF) method to arrive at the fair value, as it is the most commonly used valuation method (although methods such as acquired cost or book value, appraised or replacement cost, multiples of revenue or turnover, projected cash flow, and earnings capitalization also may be used). 


The DCF approach discounts the business’s projected cash flows to present at a rate equal to the cost of capital. It comprises:

  • Present value of cash flows during the projection period
  • Present value of the residual value at the end of the projection period
  • Value of the assets considered unnecessary to operate the newly reorganized entity, such as excess working capital or assets liquidated as part of the plan


DCF considers factors such as the discount rates adjusted to risk levels, the capital structure and market inputs, prospective financial information related to revenue growth rates and operating margins, and specific tax considerations of the emerging business.



The reorganization value differs from the enterprise value, also referred to as the market value of invested capital. Enterprise value represents the fair value of the company’s interest-bearing debt and shareholder’s equity, while reorganization value considers the impact of working capital and liabilities other than interest-bearing debt. 



For example, suppose a business has an enterprise value of $1.3 million and working capital and other liabilities amounting to $200,000. The reorganization value would be the total of the two, or $1.5 million. However, businesses emerging from bankruptcy also should evaluate other considerations, such as environmental liabilities, deferred taxes, and estimated cash balances, to arrive at an appropriately reconciled reorganization value.



A Closer Look at the Loss of Control Test


Fresh-start reporting includes considering the percentage of shares held by a shareholder before and after bankruptcy emergence. To qualify, the existing shareholder group of the predecessor company should have lost control of the emerging entity, meaning, they should not have more than a 50% controlling interest in the emerging business, but it’s not necessary to demonstrate that a single party has obtained control. 



In addition, the loss of control should be substantive and not temporary. For example, the new controlling interest must not revert to the shareholders who held interests immediately before filing or confirming the plan. When computing loss of control, potentially dilutive instruments such as share options and warrants are disregarded.



Establishing the Reporting Date


If a business emerges from bankruptcy and meets both the reorganization value test and the loss of control test, the company can begin to apply fresh-start reporting according to SOP 90-7 “as of the confirmation date, or as of the later date when all material conditions precedent to the plan’s becoming binding are resolved.” Material conditions include obtaining sufficient exit financing in the reorganization process.



While SOP 90-7 doesn’t specify a particular date for beginning fresh-start reporting, for convenience purposes and to avoid business disruption the new reporting often begins at a fiscal month-end, close to the court confirmation date or when the unresolved material conditions precedent is resolved.



The Challenges of a Fresh-start


Fresh-start reporting is an intricate process that requires careful consideration to determine the appropriate reporting dates and measure the business’s adjusted balance sheet items. If continued global challenges significantly impact future cash flows, the valuation process will become even more complex and uncertain. In turn, companies should consider only highly probable scenarios and preceding events known at the valuation date. 



Even the process of qualifying for fresh-start reporting is a challenge, requiring the business to prepare a viable and financed reorganizational plan which concludes that the emerging entity will be solvent and its operations will be feasible. SOP 90-7 also imposes strict rules and timelines for implementing fresh-start reporting.



How Scrubbed Can Help


Fresh-start reporting is a critical consideration for companies in financial distress, enabling them to start with no deficit or retained earnings and restructured assets and liabilities. But since the stakes are high and the process is complex, business leaders may find it difficult to tackle on their own. That’s where an outsourced accounting and finance firm like Scrubbed can make the difference.



Scrubbed is uniquely qualified to help companies that opt to take the fresh-start reporting approach, with the deep knowledge and experience required to overcome the potential challenges and avoid delays that could result in significant penalties. Scrubbed works with businesses emerging from bankruptcy to ensure they consider every relevant factor in pursuing reliable financial reporting, maintain effective and efficient operations, and stay compliant with laws and regulations. The Scrubbed Technical accounting Group, in partnership with our Corporate Financial Services* Group, also provides valuation assistance and thoroughly analyzes the impact of complex and unusual accounting transactions.


Are you considering leveraging the opportunity for fresh-start reporting? Contact Scrubbed to learn how we can help your business approach the fresh-start reporting process effectively.



Disclaimer

The information contained herein is general and is not intended to address the circumstances of any particular individual or entity. It is not intended to be relied upon as accounting, tax, real estate accounting solutions, or other professional services. Please refer to your advisors for specific advice. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.


*Disclaimer: Services being offered do not require a state license.


About the Author


Angel Lou Ruiz is a Senior Supervisor of the Technical Accounting Group of Scrubbed. She assists public and private companies in preparing technical memoranda, performs an extensive review of IFRS and US GAAP financial statements (i.e., 10-Q and 10-K reports), including note disclosures and account reconciliations, and provides technical accounting consultation. Before joining Scrubbed, she had nearly four years of professional experience with PricewaterhouseCoopers (PwC) Philippines handling financial statement audits, reviews, and agreed-upon procedures for public and private companies.

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Own the Core, Access the Rest: What The Future is Fractional (TFIF) 2026 Revealed About How Finance Teams Are Being Rebuilt

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Owned Layer (In-House) Accessed Layer (Fractional, Outsourced or Specialist) What it depends on Inside context, relationships, final accountability Technical depth, periodic intensity, scalable volume Examples raised at TFIF Handling new vendors and unusual charges; grant accounting; reviewing reports; approving AI-assisted work Routine transaction booking; fractional CFO leadership; merger and scaling support; cost segregation, tax credit and insurance expertise Typical role of people Review, interpret, decide Produce, execute, advise The owned layer tends to be about context and relationships. Ottavio Siani , a fractional CFO who also runs an eight-location coffee business, described the split in his own company. His on-site finance person handles anything new, like an unfamiliar vendor or an unusual charge, while an offshore team handles routine booking. The in-house role shifts, in his words, to “You will be reviewing this report. 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If we bring in outside support, how will it work with our team, and who owns that relationship? The Org Chart is Becoming a Design Decision The last generation of finance teams was built by accumulation: a new need, a new hire. TFIF 2026 suggested the next will be built by design. Leaders will decide which capabilities to own, which to access, which work technology should take on, and where a person’s judgment has to stay. That’s harder than hiring by default. It takes knowing your processes well enough to redesign them, your data well enough to trust it, and your business well enough to tell what’s core from what isn’t. The speakers who had done that work described finance functions that held up better under pressure and gave leadership answers sooner. For most finance leaders, the question is no longer whether this shift is coming. It’s which part of their own function to rethink first. Explore the TFIF 2026 conversations Want to go deeper? Each session has its own article: How We Actually Built It (Session 1) : Mid-market leaders on the signs a finance function has outgrown its structure, vetting partners, and the first 90 days of a redesign. AI in the Finance Function (Session 2) : Where AI delivers ROI today, why pilots stall, and a practical governance model for finance teams. Planning Through Permanent Uncertainty (Session 3): Rolling forecasts, scenario planning, cash reserves and keeping board confidence when assumptions shift. Real Estate Spotlight (Session 4): Cost segregation, R&D credits and insurance strategy for multi-property portfolios. Nonprofit Spotlight (Session 4): Liquidity, restricted funds, board reporting and building finance capacity on a tight budget. Technology Spotlight (Session 4): Data integrity, usage-based revenue forecasting, cash flow discipline and M&A readiness. Building Your Finance Team (Session 5): Choosing between in-house and third-party support, vetting a partner, and scaling a hybrid model. Who Spoke at TFIF 2026 Session Moderator Speakers  Keynote: The Future Is Fractional   Vince De Leon, CEO, Scrubbed  Session 1: How We Actually Built It Aira Pineda, CFO, Scrubbed Thar Casey, CEO, AmberSemi; Eric Valle, Director of Partnerships, Aduro Advisors; Marcus Guerro, President, Guerro Enterprises Session 2: AI in the Finance Function  Kendrick Kho, Chief AI Officer Rusty Canada, Partner and Co-founder, Ternpoint Solutions; Dawn Hatch, Founding Partner and CEO, Matax; Blaze O’Byrne, Co-founder, Byron  Session 3: Planning Through Permanent Uncertainty Darwin Pangilinan, Chief Client Officer, Scrubbed  Satoshi Steimetz, CFO, Playworks; Naita Saechao Chialvo, Fractional CFOO and Consultant; Danielle Morris, Founder and Chief Strategist, Triconal   Session 4: Real Estate Spotlight Ejie De Jesus, Partner, Scrubbed Geraldine Serrano, Director, Specialty Tax Group; Alex Gilmete, Commercial Property and Casualty Advisor, USI Insurance Services; Blake Peters, Founder and Principal, Peters Specialty Tax Services Session 4: Nonprofit Spotlight  Laurence Ruelo, Director of Business Development, Scrubbed  Costa John, CAO, CFO Assignments Session 4: Technology Spotlight  Anthony John Rogador, Accounting Advisory Services Manager, Scrubbed Abdul Wahab Zafar, MBA, CMA, SVP of Finance, Studycast Session 5: Building Your Finance Team  Debra Andrews, CMO, Scrubbed Ottavio Siani, Founder, Triangle Coffee, and Fractional CFO The event was hosted by Ruth Angela Dela Cruz and Fran Redoblado.

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Comparing Q3 Tax Strategies: Safe Harbor vs. Annualized Method vs. PTE Strategy Ideal for Primary Benefit Risk Level  100%/110% Safe Harbor  Rapidly growing companies  Provides protection from estimated-tax underpayment penalties when applicable safe-harbor requirements are satisfied  Low (May temporarily tie up cash if revenue drops)  Annualized Method  Seasonal or late-year spiking revenue Align tax outlays directly with timing of taxable income  Moderate (Requires meticulous record-keeping) PTE Tax Election Entities in high-tax states May provide an entity-level federal deduction for qualifying state income taxes while providing state tax benefits to eligible owners Low (Requires state-specific eligibility and election compliance) Key Takeaways: The Deadline Collision: The simultaneous timing of Q3 estimates and extended historical filings places severe strain on internal finance teams when workflows haven't scaled. 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How to Scale a Fractional CFO Practice: Infrastructure, AI, and Execution

How to Scale a Fractional CFO Practice: Infrastructure, AI, and Execution

Fractional CFOs scale by separating strategy from daily execution. At the CFO Leadership Conference in Boston, panelists outlined the model: a three-part team structure, AI tools for repetitive analysis, and strict scope boundaries. The common thread is that strategic capacity depends on reliable accounting operations underneath it. Fractional CFOs operate in a fundamentally different model, balancing multiple clients and shifting priorities without the benefit of deep organizational embedding. You are hired to provide altitude, clarity, and rapid impact. But when a client lacks a mature finance operation, that executive focus is quickly consumed by operational cleanup. This exact tension took center stage at the CFO Leadership Conference in Boston. During our morning panel discussion, The Multi-Business Executive: How Fractional CFOs Scale Leadership Across Clients , moderated by Scrubbed’s Accounting Director Arian David, Triangle Coffee founder and fractional CFO Ottavio Siani and Scrubbed’s CFO Aira Pineda detailed how fractional CFOs build capacity to avoid this operational trap. They mapped out the real-world infrastructure and AI practices required to support multiple fast-moving client environments. Here are the operational realities shared in the room. The Infrastructure Blueprint for Scaling a Fractional CFO Practice A primary challenge for scaling organizations is the gap between strategic desires and foundational accuracy. Volume increases faster than structure, and founders frequently bottleneck their own operations by micromanaging the finance function. As Aira shared with the room, stepping into a fractional role often means untangling founder-led accounting and directly telling the CEO, "you're not supposed to do this". Once leaders step back from the daily execution, "suddenly they have time" to actually focus on growing their business. Successful practitioners build a deliberate team architecture to handle the volume. To build a sustainable infrastructure, Ottavio explained that a fractional CFO setup requires three key elements: A fractional CFO to provide strategic direction. A trusted internal employee to manage sensitive operational context. An external accounting firm to run the daily numbers. This structure prevents the CFO from becoming the operational bottleneck. Read: Are Fractional CFOs the Future for Growing Companies? Navigating Risk in Founder-Led Environments The most pointed friction in a fractional role often comes from enforcing structure. During the session, an audience member challenged the panel on how to balance strict risk controls with the commercial reality of working for independent founders who operate as the "gods of their own businesses". Aira addressed this tension directly, clarifying that operational controls and commercial growth do not have to collide.  "I don't think it's contradictory, to be honest. I think it's complementary," she explained.   "I think you make better decisions as a CFO, having kind of just at the back of your mind that risk mindset." Taking calculated risks is necessary to create shareholder value. However, a fractional CFO can only support that aggressive growth when the foundational accounting operations are secure enough to absorb the complexity. Building Fractional CFO Capacity with AI Tools Technology accelerates this architecture when carefully managed. Ottavio shared how he uses Claude to generate monthly financial statement analyses based on tested templates, reducing a repetitive task to minutes. Arian detailed using Claude to abstract private equity contracts, while Aira highlighted using NotebookLM to summarize 50-page forensic documents. However, systems create results, but human professionals must validate them. Aira illustrated the danger of false confidence by testing a complex revenue recognition issue across Claude, Gemini, and ChatGPT. Although all three models provided the exact same answer, they failed the final human review when  "A big CPA firm comes and says, no, that's not the accounting treatment." Designing Aligned Execution and Preventing Scope Creep Growth adds complexity. Strong execution ensures that complexity remains manageable. When fractional leaders possess a reliable accounting layer, closes become predictable and strategic conversations gain traction. Without this layer, scope creep inevitably takes over. "I think a challenge with being a fractional CFO is having to limit your scope, right?" Ottavio noted. "I typically dedicate like a day a week, and I need to keep myself from spending too much time outside of the original scope that we, we agreed upon, so that I can make sure that I'm kind of meeting all my clients". Key Takeaways: A sustainable fractional CFO practice separates strategy from execution: the CFO, a trusted internal employee, and an external accounting team each hold a distinct role. Founders bottleneck their own operations by staying in the daily accounting. Helping them step back frees time for growth. Risk mindset and commercial growth are complementary. Calculated risks require stable accounting operations underneath them. AI tools like Claude and NotebookLM compress repetitive analysis from weeks to minutes, but experienced professionals must verify every output against source documents. Scope discipline holds only when a reliable accounting layer runs the day-to-day work. About the Panelists Arian David | Accounting Director, Scrubbed  Arian serves as the Accounting Director for Retail and Distribution at Scrubbed. She brings over 12 years of specialized execution experience managing complex accounting operations across the distribution, e-commerce, and retail sectors.  Aira Pineda | CFO, Scrubbed  Aira directs financial strategy and operations as the Chief Financial Officer at Scrubbed. She brings over a decade of hands-on experience operating as a fractional CFO for small to medium-sized enterprises. Ottavio Siani | Fractional CFO & Founder, Triangle Coffee  Ottavio is the founder of Triangle Coffee, a multi-location café business operating in Boston and Washington, D.C. As an active fractional CFO, he advises a portfolio of clients, including Hon, CN Naturals, and Port of Mocha, on building and restructuring finance teams. 

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