2017 Tax Advocacy Comment Letters
December 13, 2017 - AICPA Statement for Record of HWM Oversight Committee Hearing on IRS Reform
The AICPA offers recommendations regarding IRS governance and oversight, IRS taxpayer service and an IRS practitioner services unit, which can collectively improve the taxpayer experience.
December 8, 2017 - AICPA Comments on Tax Cuts and Jobs Act Senate
The AICPA urges Congress to move us closer to a simpler Tax Code that drives economic opportunities for individuals and families, while leveling the playing field for American businesses in the U.S.
November 21, 2017 - AICPA Comments to Senate on Tax Cuts and Jobs Act
The AICPA submitted comments to the Senate on the Tax Cuts and Jobs Act, applauding the efforts of the Senate Finance committee and highlighting key issues for consideration.
November 14, 2017 - AICPA Comments on the Portman Amendment #3 to the Tax Cuts and Jobs Act
The AICPA submitted a letter supporting Senator Portman’s Amendment #3 which would repeal certain provisions of the SFC Tax Cuts and Jobs Act, including the nonqualified deferred compensation provision of the Chairman’s mark.
November 13, 2017 - AICPA Comment Letter on the SFC Tax Cuts and Jobs Act
The AICPA submitted comments on the Senate Finance Committee Tax Cuts and Jobs Act applauding the efforts of the Committee and highlighting key issues for consideration.
November 10, 2017 - AICPA Comments on Tax Cuts and Jobs Act Ways and Means
The AICPA submitted comments on the Tax Cuts and Jobs Act, applauding the efforts of the Ways and Means committee and highlighting key issues for consideration.
October 25, 2017 - AICPA Comments on the Unified Framework for Fixing Our Broken Tax Code
The American Institute of CPAs (AICPA) supports comprehensive tax reform and appreciates your efforts in releasing the “Unified Framework for Fixing Our Broken Tax Code”. As the Administration and Congress develop legislative proposals, we encourage a holistic approach that is both equitable and meaningful to drive economic opportunities for individuals and families while leveling the playing field for American businesses not only in the United States (U.S.) but also abroad.
October 6, 2017 - AICPA Letter in Support of Title III of the National Disaster Relief Act of 2017 (H.R.3679)
The AICPA submitted a letter in support of the “Permanent Disaster Tax Relief Provisions” in Title III of the National Disaster Relief Act of 2017 (H.R. 3679). We commend both Rep. Reed and Rep. Pascrell for their continued efforts to provide permanent and consistent tax relief to individuals and businesses impacted by natural disasters. The provisions included in Title III of H.R. 3679 would provide taxpayers with more certainty, fairness, and the ability to promptly receive the relief they need after a natural disaster, while significantly reducing the administrative burdens on the IRS to react to unexpected disasters.
September 19, 2017 - AICPA Hearing Testimony on Business Tax Reform
On September 19, the AICPA requested to testify on the Business Tax Reform, suggesting that Congress provide equality, certainty, and clarity for all business owners. Businesses, regardless of entity structure, sector or the general nature of its activities, should similarly, thrive under comprehensive tax reform.
September 18, 2017 - Testimony on Centralized Partnership Audit Regime
The AICPA testified at an IRS hearing on the Centralized Partnership Audit Regime on September 18, 2017. The testimony focused on the AICPA’s recommendations and concerns about the “push-out” process for tiered partnership structures, the impact on partner capital accounts and basis, the process for designating the partnership representative and allowing an audited partnership access to the IRS Office of Appeals.
September 13, 2017 - IRS Reform: Resolving Taxpayer Disputes
The IRS Office of Appeals (“Appeals”) offers taxpayers a number of viable options to resolve a dispute (fast track settlements, early referral, fast track mediation, post appeals mediation, etc.). However, without an independent and customer-focused approach, the dispute process is intimidating, inefficient or ineffective for most taxpayers.
September 13, 2017 - AICPA Comments on Notice 2017-17
The AICPA has submitted comments to the IRS as requested by Notice 2017-17 regarding the effect on taxpayers’ methods of accounting of the new financial accounting revenue recognition standards. Our letter includes responses to the requested comments on issues of conformity between the new standards and the Internal Revenue Code and related regulations, and the requested comments on procedures for accounting method changes.
September 7, 2017 - AICPA Comments on Advance Payments Under Section 451
The AICPA has submitted comments recommending that the IRS issue regulations or other guidance to provide a single uniform treatment for advance payments under section 451. Our recommendations include providing a single regulatory provision addressing advance payments, the inclusion of advance rental payments that are not subject to section 467 as advance payments eligible for deferral, and providing an automatic consent to change to the newly allowable method.
August 23, 2017 - AICPA Comment Letter on Revenue Procedure 2015-13
The AICPA has submitted comments to the IRS regarding Revenue Procedure 2015-13, Changes in Methods of Accounting. Our comments include recommendations for items which the AICPA has identified in Rev. Proc. 2015-13 and think the IRS should revise to better achieve the goal of encouraging voluntary compliance with proper tax accounting methods, while limiting the administrative burdens of taxpayers when complying with the rules.
August 14, 2017 - AICPA Comment Letter on Centralized Partnership Audit Regime
The AICPA has submitted comments and recommendations regarding proposed regulations (REG-136118-15) issued June 14, 2017 by the IRS intended to implement the new Centralized Partnership Audit Regime created by the Bipartisan Budget Act of 2015. The AICPA provided recommendations and requested clarification on a number of the administrative provisions proposed, as well as recommendations on several additional key areas including the ability to use the “push-out” election by tiered partnership structures and how to properly reflect adjustments under the new audit regime in a partner’s basis and capital account.
August 2, 2017 - AICPA Comments on Notice 2017-38, Implementation of Executive Order 13789 (Identifying and Reducing Tax Regulatory Burdens)
AICPA has recommended that 4 of the regulation identified in the notice be withdrawn. The affected regulations are those issued under section 2704 regarding restrictions on liquidation of an interest and the valuation of interests in corporations and partnerships for estate, gift, and generation-skipping transfer tax purposes, section 385 regarding recharacterization of certain debt instruments issued between related corporations, as equity for United States (U.S.) federal income tax purposes, section 987 regarding income and currency gain or loss with respect to a qualified business unit, and section 367 regarding the exception for outbound transfers of foreign goodwill and going concern value and the application of the active foreign trade or business exception.
August 1, 2017 - AICPA Hearing Testimony to HWM Tax Policy Subcommittee on Individuals & Families
On July 19, the AICPA requested to testify on the “How Tax Reform Will Simplify Our Broken Tax Code and Help Individuals and Families”, suggesting that Congress provide sufficient time to implement transition rules (e.g., alternative minimum tax (AMT) carryovers, suspended and passive losses, etc.).
July 31, 2017 - AICPA Request to Testify on Proposed Regulations Regarding the Centralized Partnership Audit Regime (REG-136118-15, Docket ID IRS-2017-0009)
On July 31, the AICPA requested to testify at the Treasury and IRS public hearing taking place on September 18, 2017 regarding these proposed regulations. An outline of the areas on which the AICPA expects to testify is included with the request.
July 27, 2017 - AICPA Statement for the Record- SFC Hearing on Comprehensive Tax Reform: Prospects and Challenges
The AICPA submits the enclosed statement for the record of the hearing on July 18, 2017 on Comprehensive Tax Reform: Prospects and Challenges to simplify the tax system and make tax rules more understandable and accountable.
July 25, 2017 - AICPA Hearing Testimony to HWM Tax Policy Committee on Small Businesses
The AICPA submits the enclosed statement for the record of the hearing on July 13, 2017 on the How Tax Reform Will Help America’s Small Businesses Grow and Create New Jobs, considering ways to reduce the burden and complexity of tax compliance faced by small businesses to ensure that tax rules support rather than discourage growth of businesses.
July 17, 2017 - AICPA Submits Tax Reform Recommendations to Senate Finance Committee Chairman Hatch
The AICPA submitted tax reform recommendations to Senate Finance Committee Chairman Hatch on July 17 in response to his June 16 request for input from stakeholders. The AICPA’s recommendations cover a variety of topics related to taxes on individuals, families and tax administration, businesses, savings and investments, and the international tax system.
July 6, 2017 - AICPA Comments on the Definition of the Term Patient for purposes of the Definition of Patient Care
The AICPA has submitted comments requesting that the IRS issue guidance recognizing that the term “patient” encompasses individuals directly or indirectly receiving clinical diagnosis and/or treatment through telemedicine modalities and the income from the provision of telemedicine services by a tax-exempt hospital is not unrelated business taxable income.
June 22, 2017 - AICPA Letter of Support for Thune INVEST Act of 2017
The AICPA submitted a letter supporting Senator Thune’s Investment in New Ventures and Economic Success Today (INVEST) Act of 2017 (S. 1144) which was introduced in Congress on May 17, 2017. This tax reform legislation would simplify, for small and medium-sized businesses and their owners, certain accounting rules and key parts of the Internal Revenue Code.
June 20, 2017 - AICPA Letter Supporting Mobile Workforce State Income Tax Simplification Act of 2017
AICPA submitted a letter to the Members of the House of Representatives, urging support on their House floor vote on H.R. 1393, the Mobile Workforce State Income Tax Simplification Act of 2017. The House passed the bill on 6/20/17.
June 14, 2017 - AICPA Written Testimony Senate SBC Hearing on Small Business Burden
The AICPA testified on recommendations for small business tax reform at the U.S. Senate Committee on Small Business & Entrepreneurship hearing on “Tax Reform: Removing Barriers to Small Business Growth”.
June 13, 2017 - AICPA Request for Delay in Effective Date on Partnership Audit Provisions in the Bipartisan Budget Act of 2015
AICPA has requested that the United States Department of the Treasury (“Treasury”) and the IRS work with Congress to enact legislation to delay the effective date of the “Centralized Partnership Audit Regime” created by the Bipartisan Budget Act of 2015 for one year until December 31, 2018. This new Regime represents a significant departure from previous law and will require a substantial effort on the part of Treasury, the IRS, the tax practitioner community and the affected taxpayers to develop and comply with new rules, regulations and procedures to establish a fair, equitable and administrable Regime. The process of developing the necessary framework to operate the Regime is still in a very early stage and the AICPA believes that it is unlikely that all the procedures and guidance necessary for taxpayers to make informed decisions regarding its provisions will be established before the current effective date of December 31, 2017.
May 30, 2017 - AICPA Submits 2017-2018 Priority Guidance Plan
The AICPA submitted the 2017-2018 Priority Guidance Plan that identifies and prioritizes guidance projects that the Treasury Department and the IRS should address through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.
May 16, 2017 - Ensuring a Modern-functioning IRS for the 21st Century
Concerned about the degradation of IRS taxpayer service, the AICPA adopted a resolution urging policymakers to “make recommendations that enable the Internal Revenue Service (IRS) to achieve its stated mission and to transform it into a modern functioning, evolutionary, and respected federal agency for the 21st Century.
May 16, 2017 - AICPA Comments on Presidential Executive Order on Identifying and Reducing Tax Regulatory Burdens
The AICPA has submitted a list of regulations to Secretary of the Treasury Steven Mnuchin which may warrant review under the Presidential Executive Order on Identifying and Reducing Tax Regulatory Burdens issued April 21, 2017. An initial review by the AICPA identified several items as potentially imposing an undue burden on United States (U.S.) taxpayers or adding undue complexity to Federal tax laws.
May 10, 2017 - AICPA Comments on the Impact of ASU 2016-14 on the Form 990 and Related Instructions
The AICPA Exempt Organizations Taxation Technical Resource Panel submitted comments on the impact of ASU 2016-14 on the Form 990, Return of Organization Exempt from Income Tax, and the related instructions. The comments include recommendations for the IRS to update the 2018 Form 990 to reflect the financial statement reporting changes required under ASU 2016-14, for both donor restricted and quasi-endowments.
May 10, 2017 - AICPA Comments on the Form 990 and Related Instructions
The AICPA Exempt Organizations Taxation Technical Resource Panel submitted comments on the Form 990, Return of Organization Exempt from Income Tax, and the related instructions. The comments include recommendations for the 2017 forms and instructions, while indicating the importance and urgency of each recommendation.
April 26, 2017 - AICPA Comments on Tax-Exempt Organizations Group Exemptions and Filing of Information Returns
The AICPA has submitted comments to the IRS regarding exempt organizations group exemptions and the filing of information returns by organizations exempt from tax pursuant to a group exemption ruling.
April 26, 2017 - AICPA Statement for the Record for April 26, 2017 HWM Hearing on Examining the 2017 Tax Filling Season
On April 26, 2017, the U.S. House Committee on Ways & Means, held a hearing on “Examining the 2017 Filing Season,” to review efforts made by the Internal Revenue Service to provide services to taxpayers, combat identity theft, and collect taxes in the 2017 tax filing season. The AICPA submitted a statement for the record providing feedback and recommendations on IRS taxpayer services, tax-related identity theft, information reporting and Forms 1099, Individual Taxpayer Identification Numbers (ITINs), due diligence requirements, deadlines related to disasters, guidance needed on emerging issues, and other tax filing season concerns, where legislative changes can help improve future filing seasons.
April 6, 2017 - AICPA Statement for the Record for April 6, 2017 SFC Hearing on 2017 Tax Filling Season
On April 6, 2017, the U.S. Senate Committee on Finance, held a hearing on “The 2017 Tax Filing Season: IRS Operations and the Taxpayer Experience,” to address ways to improve the tax filing season, review the complexity faced by taxpayers, and examine how the IRS can better serve the public. The AICPA submitted a statement for the record providing feedback and recommendations on IRS taxpayer services, information reporting and Forms 1099, ITINs, due diligence requirements, deadlines related to disasters, guidance needed on emerging issues, and other tax filing season concerns, where legislative changes can help improve future filing seasons.
April 3, 2017 - Framework on Ensuring a Modern-Functioning IRS for the 21st Century
The AICPA, aligned with other organizations representing the tax practitioner community, is committed to focusing on solutions and how to ensure the IRS becomes the modern-functioning agency that is desired by all. We are submitting the enclosed “Ensuring a Modern-Functioning IRS for the 21st Century” framework designed to improve services provided by the IRS to taxpayers and tax practitioners. The proposed framework calls for an improved governance and oversight structure for the IRS and a new dedicated unit that would centralize the agency’s services to tax practitioners.
March 22, 2017 - AICPA Letter on Tax Technical Corrections Act of 2016
The AICPA has requested that Congress reintroduce and enact into law the Tax Technical Correction Act of 2016 previously introduced on December 6, 2016 on a bipartisan, bicameral basis during the 114th Congress. The AICPA identified the need for provisions in the bill relating to the procedures for ITIN applications by overseas taxpayers and changes to the partnership audit rules included in the Bipartisan Budget Act of 2015 to mitigate negative impacts on the IRS and taxpayers.
March 10, 2017 - AICPA Letter to Congress in Support of Mobile Workforce Legislation Committee Mark-up
AICPA submitted to Congress on March 10, 2017, a letter in support of H.R. 1393, the Mobile Workforce State Income Tax Simplification Act of 2017. The bill would provide a uniform 30 days de minimis period before withholding or state income tax liability. It was marked-up and passed by the House Judiciary Committee on March 22, 2017.
March 6, 2017 - AICPA Position Paper on State Conformity to Federal Partnership Audit Rules
AICPA developed a position paper on state conformity to federal partnership audit rules and a one pager summary on the issue. If possible, states should wait for federal clarifications before proceeding to draft and enact state specific legislation or regulations in this area. While waiting until the federal rules are further clarified, state CPA societies should start analyzing the impact of the Regime on their current state partnership audit rules. The AICPA recommends undertaking a process of identifying those state specific areas that the new Regime will impact and developing potential options to address these issues. To assist in this process, the AICPA provides recommendations that state CPA societies may want to consider as they work with their state legislatures and tax authorities.
March 6, 2017 - AICPA Position on Section 385 Regulations State Implementation Issues
AICPA developed a position paper on section 385 regulations state implementation issues and a one pager summary on the issue. State CPA societies may want to consider one pager summary suggesting that each state provide published guidance on the state treatment of the Regulations to provide certainty to taxpayers and practitioners as to whether the state will conform to, or decouple from, the Regulations.
March 6, 2017 - AICPA Position Paper on RAR (Revenue Agent’s Report) - Reporting to State Tax Authorities of Federal Tax Examination Adjustments and their Effect on State Tax Liability
AICPA submitted letter to the MTC regarding the AICPA RAR paper and request to speak about the AICPA RAR Paper at the MTC Uniformity Committee meeting on March 8, 2017. AICPA also developed a one pager summary on the AICPA RAR Position paper. The AICPA recommends states adopt guidelines and procedures to provide taxpayers with certainty and consistency. The AICPA supports the draft updated proposed Model Uniform (RAR) Statute for Reporting Adjustments to Federal Taxable Income that was submitted by the multi-organization task force to the MTC at its December 14, 2016 meeting.
March 1, 2017 - United States Senate Approval of Pending Income Tax Treaties and Protocols
The AICPA urges the Senate to approve the bilateral income tax treaties and protocols currently pending before them. The AICPA believes income tax treaties are vital to United States economic growth as well as U.S. trade and tax policy. Tax treaties are also important tools used to promote a competitive environment to attract foreign investment into the U.S. In order to serve their intended purpose, tax treaties must be kept up to date with developments in the global economy. However, several income tax treaties and protocols have been awaiting approval by the full Senate since 2010.
February 23, 2017 - AICPA Comments on Exempt Organization Unrelated Business Income Expense Allocation Methodologies for Dual Use Facilities
The AICPA has submitted comments to the IRS Office of Chief Counsel (TE/GE) regarding how a tax-exempt organization should allocate expenses attributable to facilities and/or personnel which are used for both tax-exempt activities and unrelated trade or business activities. Our comments include guidelines for allocation of indirect expenses for dual use facilities and examples.
February 21, 2017 - AICPA Comment Letter on Recommendations for S Corp Shareholder Basis Schedule
The AICPA submitted a comment letter to the Treasury and IRS to recommend that the IRS develops a required form for shareholders to attach to any income tax return which includes items of income, loss, deduction, or credit of an S corporation. This form would compute a shareholder’s basis in the stock and debt of the S corporation.
February 15, 2017 - AICPA Written Testimony on Taxation of Entrepreneurship for February 15, 2017 Hearing of the House Committee on Small Business
The AICPA testified on recommendation for small business tax reform at the U.S. House Committee on Small Business hearing on “Startups Stalling? The Tax Code as a Barrier to Entrepreneurship.”
February 1, 2017 - AICPA Letter to IRS and Treasury Thanking for Notice 2017-15 on DOMA Estate Tax Guidance
AICPA submitted a letter on Feb. 1, 2017, to the IRS and the Treasury thanking them for recently issuing Notice 2017-15, providing AICPA requested estate tax guidance to same-sex couples.
February 1, 2017 - AICPA Comments on Section 41(h) Treatment of Credit for Qualified Small Businesses
The AICPA has submitted comments to the IRS regarding section 41(h), Treatment of Credit for Qualified Small Businesses. Our comments include recommendations regarding the expansion of research credit benefits to offset certain payroll tax liabilities of start-up companies engaged in qualified research activities.
January 13, 2017 - AICPA Comments on Section 2704 Proposed Regulations on Valuation Discounts
AICPA submitted comments on 1/13/17 to Treasury and the IRS on section 2704 proposed regulations on valuation discounts.
January 4, 2017 - AICPA Comments on Section 263A(f) Interest Capitalization
The AICPA has submitted comments to the IRS regarding section 263A(f), Special Rules for Allocation of Interest to Property Produced by the Taxpayer. The comments outline recommendations to significantly reduce the complexity and administrative burden that taxpayers face in complying with the interest capitalization regulations.
January 1, 2017 - Tax Policy Concept Statement No. 1
This document provides guiding principles based on appropriate tax policies to help effectively analyze proposals and to change tax rules and tax systems. Discussions occur regularly among politicians, economists, tax practitioners, and others about changing national and sub-national tax systems. Any suggestion for modifying tax rules – whether major or minor — raises the question of how to best analyze and compare proposals. A framework of appropriate tax principles, provided in this document, is needed to analyze proposals to change tax rules and tax systems in order to best ensure an effective tax system based on good tax policy.
Tax Policy & Advocacy letters, testimony and related documents for 2013, 2014, 2015, 2016, 2018, 2019, 2020, 2021, 2022, and 2023.