2021 Tax Policy & Advocacy Comment Letters

November 18, 2021 - AICPA Comments on IRC Section 41, Research Credit Refund Claims
The AICPA is providing comments related to the significant change in requirements for a valid refund claim for research credits as announced in IR-2021-2023. We request that the IRS delay the implementation of the new requirements to provide taxpayers with a meaningful opportunity to comment before the new requirements take effect.

November 10, 2021 - AICPA Comments on House Manager's Amendment to Rules Committee Reconciliation Legislation
The AICPA provided Congress comments on various tax issues important to the accounting profession that are in the House Manager’s Amendment to Rules Committee reconciliation legislation.

November 9, 2021 - AICPA Endorsed Bipartisan LIFO Recapture Letter to Treasury
The AICPA has endorsed a bipartisan letter which urges Treasury to provide tax relief for businesses using the last-in, first-out (LIFO) inventory accounting method who cannot maintain inventory due to the global supply chain interruptions during the pandemic.

November 8, 2021 - AICPA's Comments on S. 3173, the Claiming Losses After Disasters Act
The AICPA submits comments on S.3173, the Claiming Losses After Disasters Acts. Specifically, we support the goal, encapsulated in this bill, to permanently provide disaster victims affected by a major federally-declared disaster additional tax relief for damages and losses not reimbursed by insurance.

November 2, 2021 - AICPA Letter Further Analyzing Proposed Reform(s) to Subchapter K
The AICPA is pleased to submit additional comments analyzing the Pass-through Reform Discussion Draft. We encourage the Senate to follow the House and not include Subchapter K changes in the reconciliation legislation.

October 28, 2021AICPA comments on the Corporate Profits Minimum Tax in Reconciliation Legislation Being Considered
The AICPA recommends that Congress reconsider and clarify the rules associated with the proposal regarding implementing a minimum tax on corporate adjusted financial statement income due to complexity and because it may have many significant and potentially negative implications.

October 26, 2021 - AICPA Comments on the Title VI, Sec. 80604 of H.R.3684, the Infrastructure Investment and Jobs Act
AICPA submitted comments to Congress with detailed concerns with the provision in the Infrastructure Investment and Jobs Act that would terminate the employee retention credit (ERC) for employers subject to closure due to COVID-19 by sunsetting its benefits three months early effective October 1, 2021.

October 26, 2021 - AICPA Comment Letter on Notice 2020-75, Forthcoming Regulations Regarding the Deductibility of Payments by Partnerships and S Corporations for Certain State and Local Income Taxes
The AICPA is pleased to comment on Notice 2020-75 regarding the deductibility of payments by partnerships and s corporations for certain state and local income taxes.

October 20, 2021AICPA Support for S. 2583, the Disaster Retirement Savings Act
The AICPA supports the efforts to permanently remove financial penalties for individuals impacted by natural disasters who choose to use retirement funds to cover unexpected expenses associated with those disasters.

October 8, 2021 - 2021 AICPA Compendium of Tax Legislative Proposals – Simplification and Technical Proposals
The AICPA submitted to Congress the enclosed 2021 AICPA Compendium of Tax Legislative Proposals – Simplification and Technical Proposals with a cover letter. Our focus is on changes to provisions in the IRC that need attention, recommendations that are technical in nature and recommendations that perhaps can be readily addressed.

October 1, 2021 - AICPA Comments on Tax Provisions in House Reconciliation Legislation or Being Considered
AICPA submitted comments to Congress on various tax issues important to the accounting profession and good tax policy that are in the language reported out by the House Ways and Means Committee under its jurisdiction for the reconciliation legislation or that might be considered as legislation is further considered.

September 20, 2021 - AICPA Comments on the Reporting of Depreciation Related Section 481(a) Adjustments by CFCs
The AICPA is pleased to comment on the reporting of depreciation-related section 481(a) adjustments by Controlled Foreign Corporations.

September 15, 2021 - AICPA Comments on S. 2748, the Filing Relief for Natural Disasters Act
The American Institute of CPAs (AICPA) applauds the Filing Relief for Natural Disasters Act (S. 2748) and commends the efforts to provide faster tax relief to individuals and businesses affected by natural disasters.

September 3, 2021 - AICPA supports HR 5155, “Taxpayer Penalty Protection Act of 2021”
The AICPA supports HR 5155 which provides fair and reasonable penalty relief for taxpayers impacted by COVID. The Act also reduces contact with the IRS as the services struggles with their own pandemic challenges.

August 30, 2021 - AICPA Comment Letter in support of the Support of Green Book Proposal to Modify “Tax Administration Rules” under Section 6226 and Request Similar Amendments to Section 6227
AICPA’s Comment Letter in support of the Administration’s Green Book proposal to modify “Tax Administration Rules” related to the centralized partnership audit regime passed as part of the Bipartisan Budget Act (BBA) of 2015.

August 25, 2021 - AICPA Letter to Congress on Valuation Issues and Treating Transfers of Appreciated Property by Gift or on Death as Realization Events
AICPA submitted to Congress a comment letter on valuation issues associated with the Administration’s green book proposal to reform the taxation of capital income and treat transfers of appreciated property by gift or on death as realization events.

August 24, 2021AICPA Comments on the Small Business Tax Fairness Act
The AICPA submits comments on how to improve the deduction for qualified business income under section 199A.

August 17, 2021AICPA Request for Safe Harbor Method and Expedited Relief under Section 473
The AICPA is pleased to provide details and examples of both the section 473 safe harbor method and the need for expedited relief to elect the section 473 safe harbor method.

June 30,2021AICPA Comment Letter on Tax Deadline Simplification Act
The AICPA supports changing the due dates for the second and third quarter estimated federal income tax payments to have all quarterly payments due 15 days after the end of the quarter.

June 11, 2021 - AICPA Supports the Accounting STEM Pursuit
Along with four other diverse accounting organizations, the AICPA is supporting the Accounting STEM Pursuit Act, which recognizes the accounting profession as a STEM career pathway and creates important links between accounting and STEM. The bill was introduced in Congress and supports the profession’s long-standing efforts to create more diversity in the future accounting workforce.

June 7, 2021 - AICPA Comments on Form 990, Form 990-T and 990-PF
The AICPA has provided comments on Form 990, Return of Organization Exempt from Income Tax, Form 990-T, Exempt Organization Business Income Tax Return, and Form 990-PF, Return of Private Foundation, and the related instructions to the IRS.

May 25, 2021 - AICPA Comments on Changes to Simplify and Improve the AAR Process Under the Centralized Partnership Audit Regime and Proposed “AAR-EZ” Process Framework
The AICPA is pleased to submit comments proposing an “AAR-EZ” process framework to simplify and improve the AAR process under the centralized partnership audit regime passed as part of the Bipartisan Budget Act of 2015.

May 24, 2021 - AICPA Recommendations for the 2021-2022 Guidance Priority List (Notice 2021-28)
AICPA offers our suggestions regarding the 2021-2022 Guidance Priority List.

May 17, 2021 - AICPA Comments on Additional Penalty Relief
AICPA comment letter on additional penalty relief. All taxpayers, regardless of their economic standing, deserve penalty relief measures that are fair to alleviate the current struggles with COVID.

May 11, 2021 - AICPA Comments on Proposals re: IRS Regulation of Paid Tax Return Preparers
AICPA provides recommendations on the regulation of paid tax return preparers.

May 5, 2021 - AICPA International Tax Legislative Proposals – Simplification and Technical Proposals
The AICPA actively pursues and publishes positions on a number of legislative proposals. This submission includes items focused on improving international tax administration and effectively promoting important policy objectives.

April 28, 2021 - AICPA Comment Letter Requesting Relief under Section 473
The AICPA is pleased to submit comments and recommendations requesting relief under section 473 for taxpayers that use the LIFO inventory accounting method which would allow those taxpayers to mitigate substantial and unexpected tax liabilities due to the COVID-19 pandemic.

April 13, 2021 - AICPA Comments on the Legislation to Postpone First Quarter Estimated Tax Payment Deadline for 2021
The AICPA supports H.R. 2437, the Small Business Filing Fairness Act, which would align the 2021 first quarter estimated tax payment deadline with the May 17 postponed deadline for the 2020 Federal individual income tax return filing and payment.

April 8, 2021 AICPA Suggestions on the 2021 Q1 Estimated tax and 2020 Gift Tax Extension Recommendations 
AICPA recommendations on the 2021 Q1 Estimated tax and 2020 Gift Tax Extension.

March 24, 2021 - AICPA Comments on Filing and Payment for all Taxpayers for the 2021 Filing Season
The NAEA and the AICPA are deeply disappointed that the IRS, through IR-2021-59, excludes many taxpayers from the 2021 filing season relief. In particular, the announcement ignores the challenges many small businesses and other taxpayers have suffered as a result of the pandemic.

March 23, 2021 - AICPA Requests Additional Procedural Guidance on Tax Methods & Periods Issues Related to the TCJA
The AICPA is pleased to submit comments related to the request for additional procedural guidance on tax methods and periods issues related to the Tax Cuts and Jobs Act.

March 15, 2021 - AICPA Comments to Request for Additional Guidance and Proposed Solutions for the Tax Treatment of Tax-Exempt Income from Forgiven Paycheck Protection Program Loans to Partnerships and S Corporations
The AICPA is pleased to submit comments on regarding the PPP and treatment of tax-exempt income on passthrough entity basis due to loan forgiveness.

March 11, 2021 - AICPA Comments on Global Intangible Low-Taxed Income (GILTI) Applied to Domestic Passthrough Entities under Subchapter K and Subchapter S
The AICPA provides recommendations on the application of GILTI to partnerships and S corporations, including comments on Notice 2020-69, GILTI applied to partnerships, and GILTI applied to S corporations.

March 4, 2021 - AICPA Comments on Request for Guidance on Changes to Treasury Department Circular No. 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R. Part 10)
The AICPA provided recommendations to Sharyn Fisk, Director – IRS, Office of Professional Responsibility on recommended changes to Circular 230, which contains the rules governing the practice of CPAs and other persons representing taxpayers before the IRS.

March 4, 2021 - AICPA Comments on Postponement for the Filing and Payment Deadline for the 2020 Tax Year
The AICPA urges Treasury and the IRS to act immediately to provide tax filing and payment relief for taxpayers and tax professionals affected by the ongoing pandemic. Specifically, we request that all 2020 Federal income tax, information returns, and payments (e.g., extension and estimated payments) originally due April 15, 2021 be granted additional time to file and pay until June 15, 2021.

March 3, 2021 - AICPA Comments on Request for Guidance Related to AMT Issues under the CARES Act
The AICPA is pleased to submit comments on a request for guidance related to Alternative Minimum Tax (AMT) Issues under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

February 25, 2021 - AICPA Comments on Estate Tax Closing Letters for Forms 706 and 706-NA
AICPA submitted to Treasury and IRS comments suggesting a check box on Form 706 and Form 706-NA for an estate tax closing letter request and paying the user fee when filing Form 706 and Form 706-NA. The comments are regarding proposed regulations REG-114615-16.

February 25, 2021 - AICPA Comments on the Employee Retention Credit
The AICPA comments are related to the employee retention credit as created by the CARES Act and enhanced and extended by the Consolidated Appropriations Act, has been submitted to the IRS and Treasury.

February 23, 2021 - AICPA Comments on the Certainty and Relief Needed for the 2020 Tax Year
The AICPA appreciates the efforts Treasury and the IRS have made to provide various forms of relief to taxpayers affected by the Coronavirus during 2020 (the 2019 tax year). However, as we approach the April 15 filing and payment deadline for the 2020 tax year, many taxpayers and tax professionals continue to struggle to calculate and make tax payments and prepare and file tax returns. Certainty and further relief are needed.

February 22, 2021 - AICPA Comments on the Guidance Concerning Adjustments Attributable to Conversions from S Corporations to C Corporations under section 481(d)
The AICPA is pleased to submit comments on guidance concerning adjustments attributable to conversations from S Corporations to C Corporations under section 481(d).

February 16, 2021 AICPA Comment on Underpayment and Late Payment Penalty Relief for 2020 Tax Year
AICPA urges Treasury and the IRS to provide certain taxpayers relief from underpayment and late payment penalties for the 2020 taxable year.

February 8, 2021 – Senate Expresses Support for Federal Mobile Workforce Tax Issues
The AICPA-supported Mobile Workforce State Income Tax Simplification Act was included as Amendment no. 52 (Thune-Brown) to the Fiscal Year 2021 Budget Resolution, laying the groundwork for future Senate action on the broader issue. The amendment, which is largely symbolic, passed by a unanimous voice vote on February 4, making it the first time the Senate has considered this issue. AICPA continues to support the enactment of the Mobile Workforce Act, and on August 27, 2020, AICPA and COST were joined by 120 organizations, including 45 state CPA societies, on a letter to the Congressional leadership urging the enactment of Senator Thune’s Remote and Mobile Worker Relief Act.

January 15, 2021 - AICPA Comments on the Interaction of the Employee Retention Credit and PPP Loans
AICPA comments on the interaction of the Employee Retention Credit and PPP loans as changed by the Consolidated Appropriations Act, 2021.

Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016, 2017, 20182019 and 2020.