2015 Tax Advocacy Comment Letters  



    March 23, 2015 - AICPA Offers to Congress to be a Resource on Tax Reform

    The AICPA looks forward to working with the 114th Congress and the tax-writing committees as the Congress considers tax reform.  We encourage the Congress to examine all aspects of the tax code to improve the current rules.  We stand for a code that is simple, practical, and administrable.  The AICPA has consistently supported tax reform simplification efforts because we are convinced such actions will significantly reduce taxpayers’ compliance costs and encourage voluntary compliance through an understanding of the rules.   See the attached letter for more details and links to our comments.

    We are available to Members of Congress and staff as a resource.  For example, we are available to:

    • Offer suggestions from an administrative and practical standpoint;
    • Identify potential pitfalls of a particular provision;
    • Discuss the “small business” perspective;
    • Provide informal feedback on legislative language; and
    • Support legislative provisions that are officially approved by our Tax Executive Committee.

    March 19, 2015 - AICPA Letter to IRS on Portability Relief

    This AICPA letter to the IRS requests relief for surviving spouses electing estate tax portability. The AICPA requested that Treasury and IRS:
    • Permanently allow estates below the filing threshold 15 months after the death to file Form 706 in order to elect portability;
    • Provide a short Form 706-EZ to make the portability election; and
    • Allow the surviving spouse to file Form 706 for portability, if the executor chooses not to file the form because the estate is not otherwise required to do so.  

    March 18, 2015 -
    SFC Individual Tax Reform Proposals Letter

    The AICPA sent a comment letter to the Senate Finance Committee Tax Reform Working Group (Individual Income Tax). In the interest of good tax policy and effective tax administration, we advocate for: Simplified Income Tax Rate Structure, Education Incentives, and “Kiddie Tax” Rules; Identity Theft and Tax Fraud Measures, and  Relief for Missed Elections (9100 Relief).

    March 17, 2015 - AICPA Compendium of Tax Legislative Proposals 2015

    Our focus in this 2015 Compendium of Tax Legislative Proposals is on changes to 34 provisions in the Internal Revenue Code that need attention, recommendations that are technical in nature and recommendations that perhaps can be readily addressed. This Compendium includes items focused on improving tax administration, making the tax code fairer, and effectively promoting important policy objectives.

    February 13, 2015 - AICPA Comment Letter Advance Payments Stock Acquisition

    This letter addresses two interpretive issues that the AICPA identified in the application of Rev. Proc. 2004-34 and Treas. Reg. § 1.451-5.   Specifically, this letter addresses issues related to the treatment of advance payments deferred under Rev. Proc. 2004-34 or Treas. Reg. § 1.451-5 when the stock of the taxpayer is acquired and the application of Rev. Proc. 2004-34 to advance payments received from members of an affiliated group.  The AICPA also recommends that additional guidance be issued to clarify these rules.

    February 3, 2015 -
    AICPA Requests Tax Treaty Ratification

    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. However, several income tax treaties and protocols have been awaiting approval by the full Senate since 2010.

    January 23, 2015 - AICPA Letter on Needed Statutory Authority for IRS to Grant 9100 Relief to Taxpayers

    This AICPA letter suggests Congress include in the tax reform legislation important technical changes to permit administrative relief (i.e., providing the Internal Revenue Service permission to grant “section 9100 relief”) for certain late or defective elections upon a showing of good cause by a taxpayer.  Section 9100 relief, which is currently available with regard to some elections, is extremely valuable for taxpayers who miss the opportunity to make certain tax elections.  Congress needs to provide statutory authority in order for the IRS to have authority to grant administrative relief in appropriate situations for provisions that have statutory deadlines and relief is not already authorized. 

    January 12, 2015 - AICPA Comments on the Camp discussion draft of the proposed Tax Reform Act of 2014

    Attached is the AICPA’s comment letter in response to the House Ways and Means Committee Chairman Dave Camp's discussion draft of the proposed Tax Reform Act of 2014, a tax reform legislative act.  The AICPA provides general comments on an efficient and effective tax system based on principles of good tax policy.  The AICPA also provides support for provisions such as tax reform for individuals, the repeal of the alternative minimum tax, business tax reform, participation exemption system for the taxation of foreign income, tax exempt entities and tax administration and compliance.

    View Tax Advocacy Comment Letter archives for 2014 and 2013.




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