2022 Tax Policy & Advocacy Comment Letters

May 3, 2022 - AICPA Releases Letter Announcing Endorsement of Bipartisan, Bicameral Supply Chain Disruptions Relief Act
The AICPA supports efforts by Congress to provide tax relief to businesses that have been unable to maintain inventory during the pandemic. The AICPA announces its endorsement of the bipartisan Supply Chain Disruptions Relief Act, sponsored in the House by Representatives Dan Kildee (D-MI) and Jodey Arrington (R-TX) and also in the Senate by Sherrod Brown (D-OH).

April 14, 2022 - AICPA Comments on Section 41 Research Credit Refund Claims
The AICPA has concerns about the new requirements for collection of information to obtain a valid refund claim for research credits. These requirements should be paused until the IRS obtains approval from OMB for the collection of information.

April 14, 2022 - AICPA Comment Letter of Support for Supply Chain Disruptions Act
The AICPA supports efforts by Congress to provide tax relief to businesses that have been unable to maintain inventory during the pandemic. The AICPA announces its endorsement of the bipartisan Supply Chain Disruptions Relief Act, sponsored in the House by Representatives Dan Kildee (D-MI) and Jodey Arrington (R-TX).

March 1, 2022 - AICPA Comments on Treatment of Disregarded Payments for Dual Consolidated Loss Rules under Section 1503(d)
The AICPA appreciates the opportunity to provide comments regarding a topic that we understand is under active consideration by the government, regarding the treatment of disregarded payments for purposes of the dual consolidated loss rules set forth in section 1503(d) and the related regulations.

March 1, 2022 - AICPA Notice Proposing Revenue Procedure Updating Group Exemption Letter Program (Notice 2020-36)
The AICPA is pleased to comment on Notice 2020-36, which contains a proposed revenue procedure updating the group exemption letter program.

February 24, 2022 - Concerns Regarding Schedules K-2 and K-3 Reporting
AICPA and state CPA societies call on Treasury and the IRS to delay implementation of the Schedule K-2 and K-3 to 2023 and to suspend any assessment of penalties against Partnerships of S Corporations for failing to file or failing to timely provide Schedules K-2 and K-3 for the 2021 tax year.

February 18, 2022 - AICPA Additional Comments Regarding Schedule K-2 and Schedule K-3
The AICPA submitted additional comments regarding Schedules K-2 and K-3 and also specifically addressing the IRS transition relief provided for on February 16, 2022. The AICPA recommended that the IRS delay implementation of the Schedules until 2023 and significant penalty relief for the 2022 tax filing season (2021 tax years).

February 18, 2022 - The Association of International Certified Professional Accountants comments on the Public Consultation Document – Pillar One – Amount A: Draft Model Rules for Nexus and Revenue Sourcing
The Association of International Certified Professional Accountants (“Association”) submitted comments on public consultation document Pillar One – Amount A: Draft Model Rules for Nexus and Revenue Sourcing. We continue to recommend our framework for a consensus-based, equitable, and successfully durable rebalancing of multijurisdictional taxing rights.

February 17, 2022AICPA Oral and Written Testimony at Senate Finance Committee hearing on Spotlighting IRS Customer Service Challenges
AICPA Tax Executive Committee chair, Jan Lewis testified on February 17, 2022, at the Senate Finance Committee on the hearing on Spotlighting IRS Customer Service Challenges.

February 16, 2022 - Coalition Response to Feb 8 Oversight Subcommittee Hearing on Challenges Facing Taxpayers
A Coalition for taxpayer relief urges the Oversight Subcommittee to continue to work with the IRS toward a meaningful resolution to the host of issues that have been raised by taxpayers and advocates.

February 10, 2022 - AICPA Encouraged by IRS Announcement, Continues to Urge Further Action
AICPA issued a statement that it is encouraged by the welcome step of the IRS suspending more automated notices during the processing backlog. AICPA urged consideration of additional recommendations for relief.

February 9, 2022 - AICPA Comment Letter on Deferral of Live Event Advance Payments Affected by COVID
The AICPA requests additional guidance as it applies to prepayments received by taxpayers for live events, shows or other productions that were canceled or deferred due to COVID-19.

February 4, 2022 - AICPA Comments on Proposed FinCEN Beneficial Ownership Reporting Requirements under the Corporate Transparency Act
The AICPA submitted comments to the Financial Crimes Enforcement Network (FinCEN) urging them to carefully consider the burden and cost imposed by proposed beneficial ownership information (BOI) reporting requirements affecting estimated 25 million small businesses, including small CPA firms. The AICPA encourages FinCEN to exempt all CPA firms from the reporting requirements and consider recommendations to clarify broad definitions and better align BOI reporting requirements to ease the compliance burden for small businesses.

February 3, 2022 - AICPA Statement on IRS Plans to Reassign Staff to Address Backlog
AICPA issued a statement that the recent actions taken by the IRS to suspend a notice and the press reports that they are considering additional steps – including shifting personnel to service centers – are positive steps in the right direction. AICPA urged the Service to move as quickly as possible to offer reasonable measures of relief.

January 28, 2022- AICPA Additional Comments Regarding Effective Dates in Build Back Better (BBB) Act
The American Institute of CPAs (AICPA) is pleased to submit additional comments regarding the potential impact of retroactive effective dates under the proposed tax provisions in H.R. 5376 (“Build Back Better Act” or “BBB”).

January 27, 2022 AICPA Statement on Recent IRS Announcement: ‘We Believe That There Is More They Can Do’
AICPA stated that after the coalition letter and media briefing and Congressional letter the IRS announcement of its intention to stop some notices to taxpayers as they increase resources to process backlogged files is a positive first step, but AICPA believes that more should be and could be done by the IRS, without the need for congressional action, to reduce erroneous automated notices and unnecessary taxpayer contact with the Service.

January 27, 2022Taxpayer Advocate Coalition Statement on IRS Actions Offering Limited Taxpayer Relief (Coalition statement)
The Tax Professionals United for Taxpayer Relief coalition released a statement in response to a recent announcement by the Internal Revenue Service (IRS) to suspend “some notices to taxpayers” for the upcoming tax filing season. This is a good first step in offering relief to taxpayers, but more is needed and IRS should implement all of our recommendations.

January 24, 2022Diverse Coalition of Stakeholders Media Briefing on IRS Service Issues (Coalition briefing)
The Tax Professionals United for Taxpayer Relief Coalition held a virtual media briefing to discuss IRS service issues that have caused unnecessary stress and anxiety for taxpayers throughout the COVID-19 pandemic.

January 14, 2022- Relief for Taxpayers for the 2022 Filing Season (Coalition letter)
The Coronavirus pandemic has created enormous challenges for taxpayers, tax professionals and the IRS.  Implementing reasonable penalty relief measures, that the IRS can offer immediately, are necessary to help not only taxpayers and tax professionals but also the IRS during these challenging times.

January 10, 2022 - AICPA Statement on AICPA Calls on IRS to ‘Do More’ – Pushes for Action on Relief for Taxpayers
AICPA has recommended to the IRS that they take reasonable actions that would meaningfully reduce persistent, unnecessary and erroneous notifications and help American taxpayers.”    

Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016, 2017, 20182019, 2020, and 2021.