The American Institute of CPAs (AICPA) has made more than 180 recommendations to the Internal Revenue Service (IRS) regarding the agency’s 2017-2018 Guidance Priority List.
The AICPA’s May 30 letter identifies and prioritizes guidance projects that it believes the U.S. Treasury Department and the IRS should address through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance. The recommendations cover a wide range of individual, business and exempt organization tax issues, including projects related to international, retirement and estate and trust 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.