The American Institute of CPAs (AICPA) has submitted more than 150 recommendations to the Internal Revenue Service (IRS) about items it believes should be included on the Service’s 2018-2019 Guidance Priority List.
The AICPA’s letter identifies and prioritizes guidance projects that it believes the U.S. Department of the Treasury and IRS should address through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance. The top priority recommendations relate to projects required as a result of the enactment of the Tax Cuts and Jobs Act. Additional recommendations cover a wide range of individual, business and exempt organization tax issues, including projects related to international, partnership, crowdfunding and the sharing economy, virtual currency 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. The recommendations are listed in priority order within each category.