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Exempt Organizations Tax Advocacy 

This section contains comment letters and recommendations submitted by the AICPA on legislative, regulatory and administrative matters with regards to tax returns required to be filed by tax exempt organizations.

 

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AICPA Comments on IRS Exempt Organization Enforcement Efforts

Comment Letter This April 12, 2004 letter from the AICPA Exempt Organization Taxation Technical Resource Panel to the Advisory Committee on Tax Exempt and Government Entities discusses enforcement and compliance processes and proposes a Form 990 redesign, a redesign of the exemption application process for section 501(c)(3) organizations, and new applications for
Published on April 17, 2013

AICPA 2007 Comments on Redesigned Form 990

Comment Letter AICPA comments on IRS re-designed Form 990. IRS plans to implement the new form, effective for 2009 filing season (2008 Forms 990).
Published on November 12, 2012

AICPA Urges IRS to Clarify Form 990 Instructions

Comment Letter The American Institute of Certified Public Accountants has urged the IRS to clarify its instructions on three lines of Form 990, which is the form filed by organizations that are exempt from federal income tax.   The AICPA's June 15, 2006 comments request further clarification of several parts of Form 990: lines
Published on November 12, 2012

AICPA Suggests Improvements to Form 1023

Comment Letter On December 2, 2002, AICPA makes suggestions to the IRS for improvements to Form 1023, the Application for Recognition of Exemption for nonprofit organizations.
Published on November 12, 2012

AICPA Questions IRS About Education Letters Sent to Exempts

Comment Letter March 26, 2004. This letter to the IRS Exempt Organizations Division addresses their recent sending of ""educational letters"" informing charitable organizations with contribution income that they are: (1) disclosing an amount less than 5 percent of contributions; or (2) not disclosing any fundraising expenses in Part II of Form 990.
Published on November 12, 2012

AICPA Comments on Form 990 Redesign

Comment Letter June 4, 2004. This AICPA letter to the acting director of the IRS Exempt Organizations Division makes suggestions for redesigning Form 990.
Published on November 12, 2012

AICPA Beta Tests the E-File Form 990

Comment Letter This August 22, 2003 letter to the IRS summarizes AICPA Exempt Organization Taxation Technical Resource Panel findings upon beta testing of the E-File Form 990.
Published on November 12, 2012

AICPA Asks IRS to Modify Form 990 Instructions

Comment Letter On March 31, 2006, the AICPA asked the IRS to clarify instructions for line 75c of Form 990, Return of Organization Exempt from Income Tax, believing the language to be too broad, risking unintended consequences. This document poses a number of questions regarding how the instructions apply to various common
Published on November 12, 2012

Comments on New Form 990 September 2007

Comment Letter AICPA submitted detailed observations on September 13, 2007 on the IRS draft of the redesigned Form 990 along with recommendations for improvements. While the primary focus is on forms, there are also notes on instructions and details.  The IRS intends to implement the redesigned Form 990 for 2008 tax years.
Published on November 06, 2012

March 2005 Governance Whitepaper

Comment Letter AICPA supports the Senate Finance Committee's objective of ensuring that not-for-profit organizations maintain the full confidence of the public by being accountable and fulfilling their fiduciary responsibilities.  This whitepaper was attached to a cover letter submitted in March 2005.
Published on November 06, 2012

March 2005 Comments on Governance

Comment Letter Provided are proposed comments and suggestions from the AICPA in response to concerns for reform and best practices for NPOs including but not limited to: audit thresholds, availability of financial information, auditor rotation, CEO/CFO Certification, etc.  Submitted on March 1, 2005, these comments and suggestions are made in light of
Published on November 06, 2012

July 2004 Charitable Governance Letter

Comment Letter AICPA submits comments on the Senate Finance Committee discussion draft relating to charitable governance, for the charitable governance roundtable in July 2004, stating they can't commend changes that will impose financial burdens on all exempt organization as a result of the acts of a few. They discuss the consequences.  We commend
Published on November 06, 2012

May 11, 2010 Comment on Instructions to Form 990

Comment Letter The AICPA Exempt Organizations Taxation Technical Resource Panel submitted comments on Form 990, Return of Organization Exempt from Income Tax, and its Instructions on May 11, 2010.
Published on November 06, 2012

Comments on Audit Firm Rotation for Exempt Organizations June 1, 2007

Comment Letter June 1, 2007 comment letter regarding AICPA reservations over the suggestion that audit firm rotation constitutes a good practice for exempt organizations, since it has consistently failed to gain support from the SEC, GAO, private organizations, academics, & others constituting sound public policy. Reasons are given.  IRS previously published draft
Published on November 06, 2012

May 21, 2008 Comment Letter regarding Draft 2008 Form 990 Instructions

Comment Letter AICPA provides the IRS on May 21, 2008 with comments developed by the Form 990 Instructions Task Force and approved by the Exempt Organizations Technical Resource Panel in order to improve the overall quality and implementation of the form and instructions for 2008.
Published on November 06, 2012

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