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TEC Initiatives Editor:
Since the last cut-off date for this column (Sept. 15, 2005; see TTA, November 2005), the AICPA Tax Division’s Tax Executive Committee (TEC) met once (Oct. 31, 2005) and exercised its review function on several projects. TEC actions taken after Dec. 15, 2005 will be reported in a future column. Tax Policy Advocacy The TEC plays a major role on behalf of all 350,000+ AICPA members by interacting with tax policymakers. As a senior policymaking committee, its official positions are those of the AICPA, unless the Board of Directors overrides them. These positions cover a variety of forums, including detailed reactions to proposed legislation and other official regulatory guidance. All positions are developed by experts—the volunteer members of the Tax Division’s various committees, technical resource panels (TRPs) and task forces, and AICPA staff. Proposed positions are extensively reviewed either by the TEC or a subset of its members, before they are approved as official positions. In contrast to some other professional groups, in which commentary usually represents the views of the individual members of a specific subgroup, the TRPs and committees cannot take official positions without the TEC’s endorsement, thus ensuring that positions taken represent the AICPA’s official policy. Policy studies: The TEC has issued a series of tax policy studies, intended to provide a neutral context for analyzing a variety of tax proposals; see, e.g., Tax Policy Concept Statement 1: Guiding Principles of Good Tax Policy: A Framework for Evaluating Tax Proposals, available at http://tax.aicpa.org/NR/rdonlyres/AC230E51-D650-4D65-B160-C7450A9381F4/0/2I_08a.pdf. It has also undertaken in-depth studies that address specific, broad, tax policy proposals. For example, in March 2005, it issued a Social Security reform study; see Understanding Social Security Reform: The Issues and Alternatives, available at www.aicpa.org/members/socsec.htm. Last September, fundamental tax reform was tackled; see Under-standing Tax Reform: A Guide to 21st Century Alternatives, available at http://tax.aicpa.org; see under “News and other Center Communications.” The TEC also conducts joint studies with other professional groups. For example, the report, titled Reform of Federal Wealth Transfer Taxes, was the result of collaboration among the TEC, the American Bar Association, the American Bankers Association and estate planning professional groups. The report is available at http://tax.aicpa.org/Resources/Tax+Advocacy+for+Members; click on “Trust and Estate and Gift.” Policy
studies involve significant efforts by many people. They usually have
their genesis in the Tax Division’s Tax Legislation and Policy Committee
(TLPC) (chaired by Don Barnes, and staffed by Carol Ferguson), although
sometimes the TEC suggests topics to the TLPC. The TLPC will form one or
more task forces for an in-depth look at a specific area. If necessary,
it will turn to outside resources for expertise not readily available
within the volunteer pool. For example, for the Social Security and
fundamental tax reform studies, the TLPC engaged Marty Sullivan, an
economist who specializes in tax policy analysis. This ensured the
professional generation and presentation of the study’s economic data.
For other studies, it sought out professionals who specialize in
generating revenue estimates of proposed legislative changes; see e.g.,
the fiscal-year flexibility proposal, available at
http://tax.aicpa.org/Resources/Tax+Advocacy+for+Members/AICPA+ Major studies involve a significant commitment by the TEC, Tax Division members and AICPA staff. For example, before Social Security reform and fundamental tax reform were all the rage, the TEC had already identified them as emerging issues. Its task forces in these areas (both staffed by Carol Ferguson) reviewed the TEC’s positions and identified the new efforts that would be needed to respond to changed environmental realities. Numerous conference calls, meetings and drafting sessions led to documents that needed to be reviewed by the TEC and others. The TEC’s modifications to these drafts resulted in approved and published documents. The TEC held press conferences to announce their publication. It provided electronic copies to all members of Congress and their staffs. Further, Tom Ochsenschlager, Vice President of the Tax Division, and Carol Ferguson made personal calls to key staff and members of the House Ways and Means Committee and the Senate Finance Committee, and personally delivered hard copies. Other proposals: Commentary on regulatory proposals is no less time-consuming, but it is often more compressed, due to the nature of the public comment process. Generally, the TEC’s comments on regulations or other statutory guidance commences with the TRP or committee responsible for monitoring the specific Code section involved. Once the IRS or Treasury announces its intention to take regulatory action or issue administrative guidance that requires public comment, the appropriate group determines whether commentary is needed. The decision is then reviewed by senior AICPA tax staff and, when necessary, the TEC. Once comments are prepared, they are reviewed by either the TEC or a subset of its members in cases when the comments do not involve new positions, or by the full TEC membership when there are new positions. Regulatory comment letters generally are shorter than legislative studies, and require more technical analysis. Other Activities and News
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