The recommendations listed in the May 12 letter cover a wide range of individual, business and exempt organization tax issues, including projects related to international, retirement, estate and trust, health care and employment rules.
The AICPA emphasized the importance of simplification when drafting guidance and urged the IRS to consider the following guidelines as part of the process:
- Use the simplest approach to accomplish a policy goal;
- Provide safe harbor alternatives;
- Offer clear and consistent definitions;
- Use horizontal drafting (a rule placed in one Internal Revenue Code section should apply in all other Code sections) to the greatest extent possible;
- Build on existing business and industry-standard record-keeping practices;
- Provide a balance between simple general rules and more complex detailed rules; and
- Match a rule’s complexity to the sophistication of the targeted taxpayers.
The suggestions are listed under the AICPA working group that developed them. Recommendations are listed in priority order within each category.