2017 Tax Advocacy Comment Letters 


July 17, 2017 - AICPA submits tax reform recommendations to Senate Finance Committee Chairman Hatch

The AICPA submitted tax reform recommendations to Senate Finance Committee Chairman Hatch on July 17 in response to his June 16 request for input from stakeholders. The AICPA’s recommendations cover a variety of topics related to taxes on individuals, families and tax administration, businesses, savings and investments, and the international tax system.


July 6, 2017 - AICPA Comments on the Definition of the Term Patient for purposes of the Definition of Patient Care

The AICPA has submitted comments requesting that the IRS issue guidance recognizing that the term “patient” encompasses individuals directly or indirectly receiving clinical diagnosis and/or treatment through telemedicine modalities and the income from the provision of telemedicine services by a tax-exempt hospital is not unrelated business taxable income.


June 22, 2017 - AICPA Letter of Support for Thune INVEST Act of 2017

The AICPA submitted a letter supporting Senator Thune’s Investment in New Ventures and Economic Success Today (INVEST) Act of 2017 (S. 1144) which was introduced in Congress on May 17, 2017. This tax reform legislation would simplify, for small and medium-sized businesses and their owners, certain accounting rules and key parts of the Internal Revenue Code.


June 20, 2017 - AICPA Letter Supporting Mobile Workforce State Income Tax Simplification Act of 2017

AICPA submitted a letter to the Members of the House of Representatives, urging support on their House floor vote on H.R. 1393, the Mobile Workforce State Income Tax Simplification Act of 2017. The House passed the bill on 6/20/17.


June 14, 2017 - AICPA Written Testimony Senate SBC Hearing on Small Business Burden

The AICPA testified on recommendations for small business tax reform at the U.S. Senate Committee on Small Business & Entrepreneurship hearing on “Tax Reform: Removing Barriers to Small Business Growth”.


June 13, 2017 - AICPA Request for Delay in Effective Date on Partnership Audit Provisions in the Bipartisan Budget Act of 2015

AICPA has requested that the United States Department of the Treasury (“Treasury”) and the IRS work with Congress to enact legislation to delay the effective date of the “Centralized Partnership Audit Regime” created by the Bipartisan Budget Act of 2015 for one year until December 31, 2018. This new Regime represents a significant departure from previous law and will require a substantial effort on the part of Treasury, the IRS, the tax practitioner community and the affected taxpayers to develop and comply with new rules, regulations and procedures to establish a fair, equitable and administrable Regime. The process of developing the necessary framework to operate the Regime is still in a very early stage and the AICPA believes that it is unlikely that all the procedures and guidance necessary for taxpayers to make informed decisions regarding its provisions will be established before the current effective date of December 31, 2017.


May 30, 2017 - AICPA Submits 2017-2018 Priority Guidance Plan

The AICPA submitted the 2017-2018 Priority Guidance Plan that identifies and prioritizes guidance projects that the Treasury Department and the IRS should address through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance.


May 16, 2017 - Ensuring a Modern-functioning IRS for the 21st Century

Concerned about the degradation of IRS taxpayer service, the AICPA adopted a resolution urging policymakers to “make recommendations that enable the Internal Revenue Service (IRS) to achieve its stated mission and to transform it into a modern functioning, evolutionary, and respected federal agency for the 21st Century.


May 16, 2017 - AICPA Comments on Presidential Executive Order on Identifying and Reducing Tax Regulatory Burdens

The AICPA has submitted a list of regulations to Secretary of the Treasury Steven Mnuchin which may warrant review under the Presidential Executive Order on Identifying and Reducing Tax Regulatory Burdens issued April 21, 2017. An initial review by the AICPA identified several items as potentially imposing an undue burden on United States (U.S.) taxpayers or adding undue complexity to Federal tax laws.


May 10, 2017 -  AICPA Comments on the Impact of ASU 2016-14 on the Form 990 and Related Instructions

The AICPA Exempt Organizations Taxation Technical Resource Panel submitted comments on the impact of ASU 2016-14 on the Form 990, Return of Organization Exempt from Income Tax, and the related instructions. The comments include recommendations for the IRS to update the 2018 Form 990 to reflect the financial statement reporting changes required under ASU 2016-14, for both donor restricted and quasi-endowments.


May 10, 2017 -  AICPA Comments on the Form 990 and Related Instructions

The AICPA Exempt Organizations Taxation Technical Resource Panel submitted comments on the Form 990, Return of Organization Exempt from Income Tax, and the related instructions. The comments include recommendations for the 2017 forms and instructions, while indicating the importance and urgency of each recommendation.


April 26, 2017 -  AICPA Comments on Tax-Exempt Organizations Group Exemptions and Filing of Information Returns

The AICPA has submitted comments to the IRS regarding exempt organizations group exemptions and the filing of information returns by organizations exempt from tax pursuant to a group exemption ruling.


April 26, 2017 - AICPA Statement for the Record for April 26, 2017 HWM Hearing on Examining the 2017 Tax Filling Season

On April 26, 2017, the U.S. House Committee on Ways & Means, held a hearing on “Examining the 2017 Filing Season,” to review efforts made by the Internal Revenue Service to provide services to taxpayers, combat identity theft, and collect taxes in the 2017 tax filing season. The AICPA submitted a statement for the record providing feedback and recommendations on IRS taxpayer services, tax-related identity theft, information reporting and Forms 1099, Individual Taxpayer Identification Numbers (ITINs), due diligence requirements, deadlines related to disasters, guidance needed on emerging issues, and other tax filing season concerns, where legislative changes can help improve future filing seasons.


April 6, 2017 - AICPA Statement for the Record for April 6, 2017 SFC Hearing on 2017 Tax Filling Season

On April 6, 2017, the U.S. Senate Committee on Finance, held a hearing on “The 2017 Tax Filing Season: IRS Operations and the Taxpayer Experience,” to address ways to improve the tax filing season, review the complexity faced by taxpayers, and examine how the IRS can better serve the public. The AICPA submitted a statement for the record providing feedback and recommendations on IRS taxpayer services, information reporting and Forms 1099, ITINs, due diligence requirements, deadlines related to disasters, guidance needed on emerging issues, and other tax filing season concerns, where legislative changes can help improve future filing seasons.


April 3, 2017 - Framework on Ensuring a Modern-Functioning IRS for the 21st Century

The AICPA, aligned with other organizations representing the tax practitioner community, is committed to focusing on solutions and how to ensure the IRS becomes the modern-functioning agency that is desired by all. We are submitting the enclosed “Ensuring a Modern-Functioning IRS for the 21st Century” framework designed to improve services provided by the IRS to taxpayers and tax practitioners. The proposed framework calls for an improved governance and oversight structure for the IRS and a new dedicated unit that would centralize the agency’s services to tax practitioners.


March 22, 2017 - AICPA Letter on Tax Technical Corrections Act of 2016

The AICPA has requested that Congress reintroduce and enact into law the Tax Technical Correction Act of 2016 previously introduced on December 6, 2016 on a bipartisan, bicameral basis during the 114th Congress. The AICPA identified the need for provisions in the bill relating to the procedures for ITIN applications by overseas taxpayers and changes to the partnership audit rules included in the Bipartisan Budget Act of 2015 to mitigate negative impacts on the IRS and taxpayers.


March 10, 2017 - AICPA Letter to Congress in Support of Mobile Workforce Legislation Committee Mark-up

AICPA submitted to Congress on March 10, 2017, a letter in support of H.R. 1393, the Mobile Workforce State Income Tax Simplification Act of 2017. The bill would provide a uniform 30 days de minimis period before withholding or state income tax liability. It was marked-up and passed by the House Judiciary Committee on March 22, 2017.


March 6, 2017 - AICPA Position Paper on State Conformity to Federal Partnership Audit Rules

AICPA developed a position paper on state conformity to federal partnership audit rules and a one pager summary on the issue. If possible, states should wait for federal clarifications before proceeding to draft and enact state specific legislation or regulations in this area. While waiting until the federal rules are further clarified, state CPA societies should start analyzing the impact of the Regime on their current state partnership audit rules. The AICPA recommends undertaking a process of identifying those state specific areas that the new Regime will impact and developing potential options to address these issues. To assist in this process, the AICPA provides recommendations that state CPA societies may want to consider as they work with their state legislatures and tax authorities.


March 6, 2017 - AICPA Position on Section 385 Regulations State Implementation Issues

AICPA developed a position paper on section 385 regulations state implementation issues and a one pager summary on the issue. State CPA societies may want to consider one pager summary suggesting that each state provide published guidance on the state treatment of the Regulations to provide certainty to taxpayers and practitioners as to whether the state will conform to, or decouple from, the Regulations.


March 6, 2017 - AICPA Position Paper on RAR (Revenue Agent’s Report) - Reporting to State Tax Authorities of Federal Tax Examination Adjustments and their Effect on State Tax Liability

AICPA submitted letter to the MTC regarding the AICPA RAR paper and request to speak about the AICPA RAR Paper at the MTC Uniformity Committee meeting on March 8, 2017. AICPA also developed a one pager summary on the AICPA RAR Position paper. The AICPA recommends states adopt guidelines and procedures to provide taxpayers with certainty and consistency. The AICPA supports the draft updated proposed Model Uniform (RAR) Statute for Reporting Adjustments to Federal Taxable Income that was submitted by the multi-organization task force to the MTC at its December 14, 2016 meeting.


March 1, 2017 - United States Senate Approval of Pending Income Tax Treaties and Protocols

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.


February 23, 2017 - AICPA Comments on Exempt Organization Unrelated Business Income Expense Allocation Methodologies for Dual Use Facilities

The AICPA has submitted comments to the IRS Office of Chief Counsel (TE/GE) regarding how a tax-exempt organization should allocate expenses attributable to facilities and/or personnel which are used for both tax-exempt activities and unrelated trade or business activities. Our comments include guidelines for allocation of indirect expenses for dual use facilities and examples.


February 21, 2017 - AICPA Comment Letter on Recommendations for S Corp Shareholder Basis Schedule

The AICPA submitted a comment letter to the Treasury and IRS to recommend that the IRS develops a required form for shareholders to attach to any income tax return which includes items of income, loss, deduction, or credit of an S corporation. This form would compute a shareholder’s basis in the stock and debt of the S corporation.


February 15, 2017 - AICPA Written Testimony on Taxation of Entrepreneurship for February 15, 2017 Hearing of the House Committee on Small Business

The AICPA testified on recommendation for small business tax reform at the U.S. House Committee on Small Business hearing on “Startups Stalling? The Tax Code as a Barrier to Entrepreneurship.”


February 1, 2017 - AICPA Letter to IRS and Treasury Thanking for Notice 2017-15 on DOMA Estate Tax Guidance

AICPA submitted a letter on Feb. 1, 2017, to the IRS and the Treasury thanking them for recently issuing Notice 2017-15, providing AICPA requested estate tax guidance to same-sex couples.


February 1, 2017 - AICPA Comments on Section 41(h) Treatment of Credit for Qualified Small Businesses

The AICPA has submitted comments to the IRS regarding section 41(h), Treatment of Credit for Qualified Small Businesses. Our comments include recommendations regarding the expansion of research credit benefits to offset certain payroll tax liabilities of start-up companies engaged in qualified research activities.


January 13, 2017 - AICPA Comments on Section 2704 Proposed Regulations on Valuation Discounts

AICPA submitted comments on 1/13/17 to Treasury and the IRS on section 2704 proposed regulations on valuation discounts.


January 4, 2017 - AICPA Comments on Section 263A(f) Interest Capitalization

The AICPA has submitted comments to the IRS regarding section 263A(f), Special Rules for Allocation of Interest to Property Produced by the Taxpayer. The comments outline recommendations to significantly reduce the complexity and administrative burden that taxpayers face in complying with the interest capitalization regulations.


January 1, 2017 - Tax Policy Concept Statement No. 1

This document provides guiding principles based on appropriate tax policies to help effectively analyze proposals and to change tax rules and tax systems. Discussions occur regularly among politicians, economists, tax practitioners, and others about changing national and sub-national tax systems. Any suggestion for modifying tax rules – whether major or minor — raises the question of how to best analyze and compare proposals. A framework of appropriate tax principles, provided in this document, is needed to analyze proposals to change tax rules and tax systems in order to best ensure an effective tax system based on good tax policy.


Tax Policy & Advocacy letters, testimony and related documents for 2013, 2014, 2015 and 2016.




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