2023 Tax Policy & Advocacy Comment Letters
Tax Policy & Advocacy letters, testimony and related documents for 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022.
March 17, 2023 - AICPA Comments Requesting Lookback Period for Refunds and Credits to Apply to All Disasters Going Forward
AICPA submitted comments to Treasury and IRS requesting that the IRS apply the relief given in Notice 2023-21 regarding the lookback period for allowing tax credits or refunds to all Federally declared disasters.
March 8, 2023 - AICPA Letter Supporting 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 supports the bipartisan Supply Chain Disruptions Relief Act, sponsored in the Senate by Sherrod Brown (D-OH) and Tim Scott (R-SC) and also in the House by Representatives Jodey Arrington (R-TX) and Dan Kildee (D-MI).
March 6, 2023 - AICPA Comments on Needed Guidance on IRS Notice 2020-75 and Nonpassive vs. Passive Income and Interest Expense Tracing
AICPA submitted to IRS and Treasury comments on needed guidance on IRS Notice 2020-75 and sections 469 and 163 on nonpassive versus passive income and interest expense tracing.
February 24, 2023 - AICPA Comments for Guidance Related to Changes to Section 162(m) made by the American Rescue Plan Act of 2021
The AICPA provided Treasury and the IRS with recommendations on the changes made to section 162(m) by the American Rescue Plan Act.
February 17, 2023 - AICPA Comments for IRS Consideration on AICPA Proposed FAQs on the New Digital Assets Question on the 2022 Form 1040
AICPA suggested for IRS consideration proposed frequently asked questions (FAQs) to assist taxpayers in responding to the new digital asset question on the 2022 Form 1040, U.S. Individual Income Tax Return and discussed in the instructions. Also see AICPA press release on these comments.
February 14, 2023 - AICPA Comments on Legislation Extending Expired Tax Provisions, Including the Section 174 Research and Experimental Expenditures Expensing and AICPA Press Release on the Comments
AICPA submitted to Congress a request for legislation extending expired tax provisions, including the section 174 research and experimental expenditures expensing. AICPA issued a press release on the comments.
February 13, 2023 - AICPA Comments on OMB Number: 1545-0159 on Form 3520 and Form 3520-A
AICPA submitted comments to IRS on the Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts and Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner.
February 7, 2023 - AICPA Comments on OMB Number 1545–1910 — Form 8858, Information Return of U.S. Person With Respect to Foreign Disregarded Entities; and Transactions Between Foreign Disregarded Entity of a Foreign Tax Owner and the Filer
The AICPA submitted a letter in response to a solicitation by the IRS for comments on Form 8858, requesting an exception for certain dual-resident taxpayers.
February 7, 2023 - 2023 AICPA Compendium of Tax Legislative Proposals – Simplification and Technical Proposals
The AICPA submitted to Congress our 2023 AICPA Compendium of Tax Legislative Proposals – Simplification and Technical Proposals. Our focus is on 61 changes to provisions in the IRC that need attention, recommendations that are technical in nature and recommendations that perhaps can be readily addressed.
January 25, 2023 - AICPA Comments on Prevailing Wage and Apprenticeship Requirements Under Section 45(b)(6)(B)(ii) and Other Substantially Similar Provisions
The AICPA submitted to IRS comments regarding Notices 2022-51 and 2022-61 pertaining to prevailing wage and apprenticeship requirements of certain energy credits under the Inflation Reduction Act (IRA). Recommendations call for proposed regulations that provide detailed instructions for determining and interpreting wage information, provide safe harbors for taxpayers who rely on contractors to avoid penalty assessment, and establish facts and circumstances for determining whether a taxpayer has met the good faith effort exception for apprenticeship requirements.
January 13, 2023 - AICPA Comments on Proposed Regulations to Implement Section 7803(e) Regarding IRS Independent Office of Appeals
The AICPA submitted comments to the IRS and Department of Treasury on proposed regulations that codify the role of the administrative function of appeals as the IRS Independent Office of Appeals and establish that review by Appeals is generally available to taxpayers facing a proposed deficiency.
January 6, 2023 - AICPA Letter of Appreciation for Updated Appeals Procedures for Considering First-Time Abatement (FTA) Penalty Relief on International Penalties
AICPA submitted to IRS a letter of appreciation for the IRS Independent Office of Appeals December 7, 2022 Control No. AP-08-1222-0018 updates made to section 8.11.5 (Penalties Worked in Appeals, International Penalties) of the Internal Revenue Manual, providing clarification and direction to Appeals technical employees that they have the authority to consider and, in the appropriate circumstances, recommend granting FTA penalty relief relating to Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, and Form 5472, Information Return of a Foreign Owned Corporation.
