2024 Tax Policy & Advocacy Comment Letters

Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016, 2017, 20182019, 202020212022, and 2023.

 

July 5, 2024 - AICPA Comments on Foreign Trust Proposed Regulations and Request to Testify
AICPA submitted to Treasury and IRS comments on the foreign trust proposed regulations (REG-124850-08). AICPA also requested to testify on these proposed regulations at the 8/21/24 IRS hearing on the proposed regulations.

July 3, 2024 - AICPA Comments on Proposed Regulations on Excise Tax on Repurchase of Corporate Stock
The AICPA submitted to the Department of Treasury and IRS comments on proposed regulations on Excise Tax on Repurchase of Corporate Stock.

July 3, 2024 - AICPA Comments on Request for Clarification on Form 4626, Part V
The AICPA is submitting a request to clarify the instructions of Form 4626, Alternative Minimum Tax—Corporations, to provide that corporations that have already determined themselves to be an “applicable corporation” for purposes of the corporate alternative minimum tax may skip Form 4626, Part V, Members of a Controlled Group Treated as a Single Employer and Foreign-Parented Multinational Group (FPMG) Members Taken Into Account in “Applicable Corporation” Determination.

July 1, 2024 - AICPA Comments on Draft Form 1099-DA, Digital Asset Proceeds from Broker
The AICPA recommends simplifying Form 1099-DA in an understandable manner to taxpayers and reducing the information requested to necessary information.

July 1, 2024 - Proposed Rule: Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers
In response to the FINCEN/SEC proposal, these letters sent to the Financial Crimes Enforcement Network and U.S. Securities and Exchange Commission address concerns of redundant duties when a Registered Investment Advisor (RIA) holds all their investments with a custodian and the significant administrative burden on small CPA firms that are also small RIAs.

June 28, 2024 - AICPA Submit Recommendations on Centralized Partnership Audit Regime, Including Related Forms and Schedules
AICPA sends Treasury and IRS recommendations to continue to improve the implementation of the centralized partnership audit regime.

June 13, 2024 - AICPA Comments on Form 4797, Sales of Business Property - OMB Control Number 1545–0184
The AICPA submitted comments to Treasury and the IRS on Form 4797, Sales of Business Property, specifically, recommending clarity to the Instructions for Form 4797.

May 30, 2024 - AICPA Provided a Submission of 61 Tax Legislative Proposals to Yale Tax Reform Project
AICPA provided a submission of 61 tax legislative proposals, 14 updated disaster relief tax legislative proposals, and additional items for the Yale Tax Reform Project to consider.

May 17, 2024 - AICPA Comments on 2024-2025 IRS Priority Guidance Plan
AICPA submitted to IRS comments on the 2023-2024 IRS Priority Guidance Plan, listing 189 items of suggested and needed guidance.

April 26, 2024 - AICPA Suggestions Regarding the Tax Classification of Purpose Trusts
AICPA suggested Treasury and IRS consider suggestions regarding the tax classification of purpose trusts, and functionally similar structures, for federal income tax purposes. Our recommendations will simplify filing for taxpayers and practitioners and will reduce the administrative burden on the IRS as well.

April 23, 2024 - AICPA Comments on Proposed Regulations Related to Long-Term, Part-Time Employee Rules for Cash or Deferred Arrangements Under Section 401(k) [REG 104194-23]
The AICPA provided feedback to the IRS on the proposed regulations related to the changes made to the rules by SECURE 2.0, regarding long-term, part-time employees in relation to when they are permitted to participate in an employer-sponsored, tax-qualified retirement plan.

April 16, 2024 - AICPA Letter to Congress Supporting H.R. 8007, the Disaster Tax Lookback Parity Act of 2024
The AICPA submitted a letter to Congress in support of H.R. 8007, the Disaster Tax Lookback Parity Act of 2024.

April 15, 2024 - AICPA comments on Proposed Rule: Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers
The AICPA Personal Financial Planning Executive Committee comments in response to FINCEN-2024-0006 and RIN 1506-AB58, Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers as proposed by the Financial Crimes Enforcement Network (FinCEN) on February 15, 2024.

April 4, 2024 - AICPA Comments on Form 990 Series
The AICPA submitted 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 Related Instructions.

April 3, 2024 - AICPA letter requesting delayed enforcement of BOI reporting
The AICPA asks that FinCEN suspend all enforcement actions until one year after the conclusion of all court cases related to NSBA v. Yellen.

April 2, 2024 - AICPA Comments on the Election Out of Generation-Skipping Tax (GST) Exemption Deemed Allocations

AICPA submitted to Treasury and IRS comments on the election out of Generation-Skipping Tax (GST) exemption deemed allocations.

March 4, 2024 - AICPA Requests Guidance Related to Section 461(l) – Limitation on Excess Business Losses of Noncorporate Taxpayers
The AICPA submitted updated comments requesting guidance related to section 461(l) – Limitation on Excess Business Losses of Noncorporate Taxpayers. These comments update and replace the prior comments submitted on February 28, 2019.

March 4, 2024 - AICPA Submits Additional Comments on the Proposed Section 6045 Regulations on Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions
The AICPA submitted to Treasury and IRS additional comments on the proposed regulations on section 6045 regarding gross proceeds and basis reporting by brokers and determination of amount realized and basis for digital asset transactions (REG-122793-19, August 29, 2023). These comments are in addition to the comments submitted on November 8, 2023.

February 12, 2024 -  AICPA Comments on Form 5472 E-Filing for Foreign-Owned U.S. Disregarded Entity
AICPA submitted to Treasury and IRS comments recommending foreign-owned U.S. disregarded entity be allowed to electronically file their Form 5472 with their U.S. federal income tax return.

February 12, 2024 - AICPA Comments on REG-132422-17, Income and Currency Gain or Loss With Respect to a Qualified Business Unit
AICPA Comments on REG-132422-17, Income and Currency Gain or Loss With Respect to a Qualified Business Unit.

February 8, 2024 -  AICPA comments on Notice 2023-80 Guidance Regarding the Foreign Tax Credit and Dual Consolidated Losses in Relation to the GloBE Model Rules, and Extension and Modification of Temporary Relief in Notice 2023-55
AICPA submitted to Treasury and IRS comments and recommendations regarding the foreign tax credit and dual consolidated losses in relation to Pillar Two (Notice 2023-80, published on December 11, 2023).

February 5, 2024 - AICPA Comments on Needed Guidance on International Information Reporting for Domestic Grantor Trusts
AICPA submitted to IRS comments on needed guidance on international information reporting for domestic grantor trusts.

January 30, 2024 - AICPA Comments on FBAR Extensions for Taxpayers Affected by Major Disasters
AICPA provided feedback and recommendations to the IRS and FinCEN on FBAR filing extensions for taxpayers affected by major disasters.

January 29, 2024 - AICPA Comments on Proposed Regulations Dealing with Donor-Advised Funds
AICPA submitted feedback and recommendations to the Treasury and the IRS on the proposed regulations dealing with Donor Advised Funds (REG-142338-07).

January 17, 2024 - AICPA Comments on Notice 2023-62 Guidance on Section 603 of the SECURE 2.0 Act with Respect to Catch-up Contributions
The AICPA sent recommendations to Treasury and the IRS on Notice 2023-62 which addresses changes made to catch-up contributions by the SECURE 2.0 Act of 2022. The SECURE 2.0 Act of 2022 requires certain catch-up contributions to be made as Roth IRA deferrals. In turn, this mandates that retirement plans permitting catch-up contributions must offer a Roth contribution feature to their plan. Our comments focus on the administrability of the changes to catch-up contributions due to the addition of the Roth IRA deferral mandate.