2018 Tax Advocacy Comment Letters

February 22, 2018Technical Corrections Regarding Pub. L. No. 115-97
The AICPA respectfully recommends Congress address technical corrections on various provisions under Pub. L. No. 115-97 (Tax Cuts and Jobs Act), which revised many sections of the IRC. We have highlighted preliminary areas that need technical corrections.

February 21, 2018AICPA Comment Letter Request for Immediate Guidance Regarding IRC Section 199A
The AICPA requested immediate guidance from the Internal Revenue Service (IRS) and U.S. Department of the Treasury on various issues regarding section 199A of the new Internal Revenue Code, the deduction for qualified business income (QBI) of pass-through entities. The letter also included a list of other issues affecting QBI that the AICPA believes warrant guidance.

Specifically, the letter recommended immediate guidance on the following issues:
I. Definition of section 199A QBI
II. Aggregation method for calculation of QBI of pass-through businesses
III. Deductible amount of QBI for a pass-through entity with business in net loss
IV. Qualification of wages paid by an employee leasing company
V. Application of section 199A to an owner of a fiscal year pass-through entity ending in 2018
VI. Availability of deduction for Electing Small Business Trusts (ESBTs)

February 8, 2018 - AICPA Request for Penalty Relief for First-Time Filers of Form 5471
The AICPA has urged the Internal Revenue Service to provide prospective penalty relief to any first-time filer of Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, whose filing obligation results solely from the imposition of “downward attribution” created by the provisions of Public Law No. 115-97 (commonly referred to as the Tax Cuts and Jobs Act).

February 8, 2018AICPA Statement for Record of HWM Hearing on Legislation to Improve Tax Administration
The AICPA applauds the leadership taken by the House Ways and Means Oversight Subcommittee to consider legislative solutions related to reforming the Internal Revenue Service. We are committed to supporting Congress in its efforts and provide a series of recommendations that will strengthen tax administration and improve compliance programs while protecting the public.

January 30, 2018AICPA Comments on Ensuring Treasury/IRS has the Resources to Provide Taxpayer Service and Guidance
The AICPA urges Congress to ensure that Treasury and the IRS have the appropriate resources to provide necessary guidance and timely taxpayer assistance on the recently-passed tax reform legislation 

January 29, 2018 - AICPA Request for Immediate Guidance Regarding Pub. L. No. 115-97
The AICPA respectfully requests immediate guidance on various provisions regarding Pub. L. No. 115-97, which revised many sections of the IRC. We have highlighted some of the specific areas that need immediate guidance in order for taxpayers and practitioners to comply with their 2017 tax obligations and to make informed decisions regarding cash-flow, entity structure, retirement, wealth transfer and a vast number of other tax planning issues.

January 4, 2018AICPA Request for Delay of Effective Date of BBA Partnership Audit Provisions
AICPA has reiterated its request that Congress enact legislation to delay the effective date of the “Centralized Partnership Audit Regime” created by the Bipartisan Budget Act of 2015 for one year.


Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016 and 2017.