2019 Tax Advocacy Comment Letters
January 8, 2019 Modified: June 7, 2019
December 19, 2019 - AICPA Comments on Section 1371(f) of the Internal Revenue Code (REG–131071–18)
AICPA submitted comments to IRS on section 1371 proposed regulations on eligible terminated S corporations
December 19, 2019 - AICPA Comments on Section 382(h) Related to Built-in Gain and Loss [REG-125710-18]
The AICPA submitted recommendations related to the proposed regulations on section 382(h).
December 2, 2019 - The Association comments on the Public Consultation Document – Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two
The Association submitted comments on the public consultation document on the Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, as well as, the three components of an undertaxed payments rule, a switchover rule, and a subject to tax rule.
November 20, 2019 - AICPA Comments on Section 162(q) - Payments Related to Sexual Harassment and Sexual Abuse
The AICPA is pleased to submit recommendations regarding payments related to sexual harassment and sexual abuse under section 162(q). The AICPA understands and agrees with the public policy and intent behind section 162(q). The AICPA is commenting from the perspective that clarification of wording is important for equity purposes to ensure that all taxpayers subject to this disallowance rule will apply it consistently.
November 20, 2019 - AICPA Comments on Form 990, Form 990-T and Related Instructions
The AICPA is pleased to provide comments on Form 990, Return of Organization Exempt from Income Tax, and the related instructions and Form 990-T, Exempt Organization Business Income Tax Return, and the related instructions.
November 20, 2019 - AICPA Suggestions on Draft Form 1065 & Schedule K-1 and Related Instructions
The American Institute of CPAs (AICPA) is pleased to submit suggestions on draft Form 1065, U.S. Return of Partnership Income, draft Schedule K-1 (Form 1065), Partner’s Share of Income, Deductions, Credits, etc., and related instructions.
November 19, 2019 - AICPA Comments on Notice 2018-67 Regarding the Calculation of Unrelated Business Taxable Income under Section 512(a)(6) for Exempt Organizations
The AICPA is pleased to submit recommendations related to Notice 2018-67 - Request for Comments Regarding the Calculation of Unrelated Business Taxable Income under Section 512(a)(6) for Exempt Organizations with More than One Unrelated Trade or Business; Interim and Transition Rules for Aggregating Certain Income Investments; and the Treatment of Global Intangible Low-Taxed Income Inclusions for Purposes of the Unrelated Business Income Tax.
November 18, 2019 - AICPA Comments on Automatic Extension of Filing Deadlines for Taxpayers Affected by Federally Declared Disasters
The AICPA thanked U.S. Representative Tom Rice (R-S.C.) in a letter for his continued efforts to provide permanent and consistent tax relief to individuals and businesses affected by natural disasters. The letter expressed support of the Congressman’s goal – encapsulated in Sec. 7 of H.R. 3287 (Tax Relief and Expedited Assistance for Disasters (TREAD) Act) – that would mandate an automatic extension of certain federal tax deadlines for taxpayers affected by federally declared disasters.
November 11, 2019 - The Association comments on the Public Consultation Document – Secretariat Proposal for a “Unified Approach” under Pillar One
The Association submitted comments on the public consultation document Secretariat Proposal for a “Unified Approach” under Pillar One, as well as, input on four elements necessary to develop a consensus-based, equitable, and successfully durable rebalancing of multijurisdictional taxing rights.
October 4, 2019 - The Associations Comments on Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy
The Association of International Certified Professional Accountants (“Association”) submitted comments to OECD on its Programme of Work to Develop a Consensus Solution to the Tax Challenges.
September 19, 2019 - AICPA Comment Letter on 965 Elections
The AICPA submitted comments requesting tax reform administrative relief for section 965 elections and transfer agreements. Specifically, we recommend that Treasury and the IRS:
- Provide a process to obtain relief for late-filed or incomplete elections under sections 965(i) and 965(h) upon the triggering event of section 965(i) election;
- Allow reasonable cause or section 9100 relief for late-filed or incomplete transfer agreements under section 965(i)(2); and
- Provide a process to obtain relief for late or incomplete elections under section 965(h).
September 10, 2019 - AICPA Comments on Proposed Regs. on Investing in Qualified Opportunity Funds [REG-120186-18]
The AICPA submits our recommendations on the proposed regulations related to investing in Qualified Opportunity Funds (REG-120186-18).
September 5, 2019 - AICPA Comment Letter on Section 199A Treasury Regulations for Cooperatives and Their Patrons
The AICPA submitted comments on guidance concerning the proposed section 199A regulations for cooperatives and their patrons. The comments cover issues including the definition of patronage and nonpatronage through the directly related use test, allocation of C corporation patron deduction, electing out of the section 199A deduction, determination of income received from cooperatives, qualified payments, and qualified activities.
August 14, 2019 - AICPA Comments on Guidance Concerning Adjustments Attributable to Conversions from S Corporation to C Corporation under Section 481(d)
The AICPA recommends that Treasury and the IRS provide administrative guidance on the potential application of section 481(d) to receivables owned by the newly formed corporation that results from the termination of a QSub election with respect to a subsidiary owned by an eligible terminated S corporation.
July 24, 2019 - AICPA Comments on DAF Notice 2017-73
The AICPA is pleased to submit recommendations related to the changes to section 4967 that address certain longstanding issues regarding donor-advised funds (DAFs) and their sponsoring organizations.
July 15, 2019 - AICPA Comments on Revenue Procedure 2018-40 – Request for Comments and Impact of Pub. L. No.
115-97 on Accounting Methods for Small Business Taxpayers
The AICPA is pleased to submit recommendations as requested in Rev. Proc. 2018-40 on the small business taxpayer accounting method issues.
June 5, 2019 - AICPA Comments on 162(m) Written Binding Contract
The AICPA submitted comments to the IRS related to the definition of a written binding contract as it relates to the changes made to section 162(m) by the Tax Cuts and Jobs Act.
June 5, 2019 - AICPA comments on the 2019-2020 Guidance Priority List
The American Institute of CPAs (AICPA) is pleased to offer our suggestions regarding the 2019-2020 Guidance Priority List.
June 4, 2019 - AICPA Comments on Filing Relief for Natural Disasters Act (S. 1677)
June 4, 2019 - AICPA Comments on Filing Relief for Natural Disasters Act (H.R. 2976)
The AICPA submitted a letter in support of H.R. 2976, the Filing Relief for Natural Disasters Act introduced by Representative Chu and Representative Katko and a letter in support of S. 1677, introduced by Senator Perdue and Senator Cortez Masto. We appreciate that the Act provides the IRS the authority to postpone federal tax deadlines by reason of state-declared disasters or emergencies.
May 28, 2019 - Comments on the OECD Public Consultation Addressing the Tax Challenges of the Digitalisation of the Economy
The Association of International Certified Professional Accountants (the Association) has submitted comments and recommendations to the Organization for Economic Co-operation and Development’s (OECD) public consultation on how to address the taxation of a global, digital economy.
May 23, 2019 - AICPA Comments on the 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.
May 14, 2019 - AICPA Comment Letter On Notice 2018-99 - Parking Expenses for Qualified Transportation Fringes
The AICPA has provided comments and recommendations on the changes to section 274(a)(4) and the enactment of section 512(a)(7) in response to Notice 2018-99– Parking Expenses for Qualified Transportation Fringes. This letter is in response to the request by the IRS and Treasury for comments on the rules described in the Notice.
May 8, 2019 - AICPA Comments on Rev. Proc. 2018-31, List of Automatic Accounting Method Changes
The AICPA has submitted recommendations with respect to Rev. Proc. 2018-31, which provides a list of accounting method changes for which automatic consent is granted.
April 9, 2019 - AICPA Comments on 199A Safe Harbor and Final Regs
The AICPA submits comments on guidance concerning the deduction for qualified business income under section 199A in areas including: safe harbor for rental real estate, deemed trade or business for all commonly-owned arrangements, allocation based upon gross receipts, unadjusted basis immediately after acquisition on section 734(b) adjustments, and definition of qualified business income.
April 3, 2019 - AICPA Comments on Form 461 Instructions
The AICPA submitted our recommendation on the 2018 Instructions for Form 461, Limitation on Business Losses, dealing with application of the new loss limitation of section 461(l).
March 28, 2019 - Traps for the Unwary: Tax Cuts and Jobs Act Changes
The AICPA has developed and published a listing of traps for the unwary from the Tax Cuts and Jobs Act changes. It identifies and details a list of 21 changes together with perhaps unexpected nuances, including the qualified business income section 199A changes and clarification issues discussed in further detail in Feb. 21, 2018, Oct. 1, 2018, and April 9, 2019 AICPA comment letters to IRS on section 199A guidance.
March 26, 2019 - AICPA Comments on Proposed Foreign Tax Credit Regulations (REG-105600-18)
The AICPA has submitted comments to the IRS on proposed guidance related to the foreign tax credit. The recommendations focus on clarifications of the proper FTC basket to assign various categories of income and expenses as a result of changes made by the Tax Cuts and Jobs Act.
March 20, 2019 - AICPA Recommendations for Tax Law Changes to Reflect How Small Businesses Operate in the Modern World
The AICPA has published a position paper that offers 13 recommendations for tax law changes to reflect how small businesses operate in the modern world. These recommendations simplify start-up phase tax rules, reduce operating costs, improve equity of how tax rules operate among business entity types and help the tax system to better meet principles of good tax policy.
March, 1, 2019 - AICPA Comments to the Organization for Economic Cooperation and Development
The Association of International Certified Professional Accountants has submitted comments to the Organization for Economic Cooperation and Development in response to a consultation paper on Addressing the Tax Challenges of the Digitalisation of the Economy.
February 28, 2019 - AICPA Comments on Sec 461(l) Limitations on Excess Business Losses
The AICPA acknowledges the IRS’s efforts in issuing Information Release 2018-254 (IR-2018-254) and draft instructions for the 2018 Form 461. However, we request the issuance of much-needed substantial guidance for 461(l) in areas including: operating principles, definitions related to business income, definitions related to business deductions and losses, treatment of gains and losses, treatment of qualified plans, treatment of industry specific issues, and application to trusts and estates.
February 27, 2019 - Association Response: HM Treasury Digital Services Tax Consultation
The Association of International Certified Professional Accountants has submitted comments to the UK government in response to a consultation paper on a proposed Digital Services Tax.
February 21, 2019 - AICPA comments on section 163(j) proposed regulations
The AICPA submits their recommendations and observations on the proposed regulations regarding the business interest expense limitation.
February 19, 2019 - AICPA Comments on the Taxpayer Penalty Protection Act of 2019 (H.R. 1300)
The AICPA supports the Taxpayer Penalty Protection Act of 2019 (H.R. 1300) and commends the efforts to assist taxpayers as they deal with numerous and challenging changes resulting from Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
February 15, 2019 - AICPA Comments on Proposed Regulations Regarding Estate and Gift Taxes and the Difference in the Basic Exclusion Amount
AICPA comments on the proposed regulations (REG-106706-18) regarding the increased basic exclusion amount for estate and gift taxes.
February 13, 2019 - AICPA Comments on Small Business Relief from Definition of Tax Shelter
AICPA requests that Treasury and the IRS provide certain small businesses relief from the definition of a tax shelter to ensure that they will qualify for the small business simplifying provisions available under Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
January 28, 2019 - AICPA Comments on the Penalty Relief Needed for Taxpayers for 2018 Filing Season
The AICPA urges Treasury and the IRS to provide additional and more extensive underpayment and late payment penalty relief to taxpayers who are unable to adjust their withholding and estimated tax payments for the 2018 tax year due to the changes resulting from Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
January 24, 2019 - AICPA Letter on Effect on Taxpayers and Tax Practitioners of the Shutdown of the Internal Revenue Service
The AICPA recognizes the inherent and systemic limitations, both Treasury and the IRS face during the shutdown. Our members have expressed concerns regarding the effect of the shutdown of the Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) on taxpayers and tax practitioners.
January 24, 2019 - AICPA Proposed Regulations on Investing in Qualified Opportunity Zones (REG-115420-18)
The AICPA has submitted comments and recommendations to the IRS related to the proposed regulations on Investing in Qualified Opportunity Zones (REG-115420-18) which provide guidance on the deferral of gains resulting from a taxpayer’s investment in a Qualified Opportunity Fund.
January 10, 2019 - AICPA Comments on Proposed Guidance Related to Section 951A (Global Intangible Low-Taxed Income) (REG-104390-18)
The AICPA has submitted comments to the IRS on proposed regulations under section 951A of the Tax Cuts and Jobs Act (a/ka/ the GILTI regime). The recommendations focused on carryforward of net tested losses, several proposed anti-abuse provisions and the interaction with the section 245A Dividends Received Deduction.
January 9, 2019 - AICPA Comments on the Relief from Sections 6654 and 6655 Penalties for Specified Taxpayers
The AICPA has requested Treasury the IRS provide relief for estimated tax penalties imposed under section 6654 and 6655 for any taxpayer subject to the provisions of section 965 as enacted by the Tax Cuts and Jobs Act (TCJA).
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