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Tax Methods & Periods

Tax Methods and Periods 

This section contains comments and recommendations submitted by the AICPA on legislative, regulatory and administrative matters concerning tax accounting methods and periods.

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AICPA Testified 05.09.2012 regarding Deduction and Capitalization of Tangible Property Expenditures

Testimony AICPA testified before the IRS and Treasury at the May 9, 2012 public hearing on proposed and temporary regulations under IRC sections 162(a), 168, and 263(a) regarding the deduction and capitalization of expenditures related to tangible property, REG-168745-03 and TD 9564, and Revenue Procedures 2012-19 and 2012-20.
Published on June 04, 2013

AICPA Proposes Fiscal Year Flexibility for Emerging Small Businesses

Comment Letter This is AICPA's statement in support of allowing small businesses the flexibility to adopt any fiscal year end from April through November for tax purposes, as proposed in the Small Business Tax Flexibility Act of 2003 (H.R. 3225) for the record of the Subcommittee's September 23, 2004, hearing.
Published on May 20, 2013

AICPA Suggests Improvements to New Cash Accounting Method Notice 2001-76

Comment Letter The AICPA comment letter of 02.28.2002 requests that the IRS clarify and refine Notice 2001-76, which expanded the application of the cash method of accounting to certain businesses with revenues of less than $10 million.
Published on May 20, 2013

AICPA Comments on INDOPCO Regs

Comment Letter This letter provides AICPA's comments on the proposed INDOPCO regulations.
Published on May 20, 2013

AICPA Comments on Eligible Property and Simplified Service Cost Method Guidance From IRS

Comment Letter AICPA's response 01.27.2004 to IRS' requests for comments on Simplified Service Cost Method (SSCM) under Section 263A regulations.
Published on May 20, 2013

AICPA Asks IRS to Clarify and Improve Intangible Asset Automatic Consent Procedures

Comment Letter AICPA comments 08.24.2004 regarding the requirements found in Section 4.02 of Revenue Procedure 2004-23.
Published on May 20, 2013

AICPA Comment Letter - Proposed Regulations Under Section 6655, April 2006

Comment Letter Comments on Proposed Regulations under Section 6655 Relating to Corporate Estimated Tax [REG-107722-00]
Published on May 02, 2013

AICPA Comment Letter - I.R. 2004-14, Proposed Schedule M-3

Comment Letter
Published on May 01, 2013

AICPA Comment Letter Regarding The Retail Inventory Method of Accounting

Article On December 13, 2012, AICPA submitted comments to IRS and Treasury on the retail inventory method of accounting (REG-125949-10).  The AICPA comments address cost complement measurement period, treatment of beginning inventory under the LIFO retail inventory method, scope of retail inventory method, markdown allowances and margin protection payments, treatment of
Published on December 31, 2012

Comments on Documenting Success-Based Fees

Comment Letter AICPA comment letter of 01.10.2007 asking the IRS to publish a Rev. Rul. or Rev. Proc. permitting documentation other than time sheets to satisfy the documentation requirements for deductibility of success-based fees.  Documentation requirement under reg. section 1.263(a)-5(f), providing discussion on the IRS's inconsistent position on the matter, recommendations for clarification
Published on October 01, 2012

Comments on Rev. Rul. 2005-42 regarding Capitalization of Environmental Remediation Expenditures

Comment Letter AICPA comments of 01.30.2006 advising the IRS against capitalizing environmental remediation costs under Sec. 263A.  AICPA offers comments highlighting significant tax policy and administrative concerns regarding Rev. Rul. 2005-42, which generally requires capitalization of environmental remediation expenditures under 263A.
Published on October 01, 2012

Comments on Notice 2007-88 regarding New Procedures for Filing Form 3115

Comment Letter AICPA comments of 01.31.2008 regarding Notice 2007-88, offering suggestions to IRS for improving the processing of tax accounting method changes, including the reasons for believing that making most accounting method change requests automatic is not the solution for the backlog in processing advance consent accounting method change requests filed on Form
Published on October 01, 2012

Rolling Average Cost 01.19.2006 Comment Letter

Comment Letter Provided are comments from the AICPA on January 19, 2006, regarding the government's intent to issue guidance addressing the use of rolling average cost in response to Notice 2005-25.  The AICPA opposes a ban on the use of the rolling average cost method to calculate inventory cost.
Published on October 01, 2012

Comments on Sec. 199 Proposed Regulations

Comment Letter AICPA offers comments 01.05.2006 on the Section 199 proposed regulations offering guidance on the new domestic manufacturing deduction.  AICPA identifies aspects of the proposed regulations that require additional clarification or refinement and believe it is essential for the IRS and Treasury to provide additional guidance on certain aspects of section
Published on October 01, 2012

Comment Letter on TAM 200603027 regarding LIFO Inventory Method

Comment Letter AICPA comment letter of 05.02.2006 regarding TAM 200603027 involving "last-in, first-out" (LIFO) inventory method.  AICPA believes requiring a taxpayer to expand its ""Last-in, First-out"" election to include all items within its dollar-value Inventory Price Index Computation (IPIC) pools is improper in light of a plain reading and basic interpretation of the
Published on October 01, 2012

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