2019 Tax Advocacy Comment Letters

January 8, 2019 Modified: June 7, 2019

June 5, 2019 - AICPA Comments on 162(m) Written Binding Contract
The AICPA submitted comments to the IRS related to the definition of a written binding contract as it relates to the changes made to section 162(m) by the Tax Cuts and Jobs Act.

June 5, 2019AICPA comments on the 2019-2020 Guidance Priority List 
The American Institute of CPAs (AICPA) is pleased to offer our suggestions regarding the 2019-2020 Guidance Priority List.

June 4, 2019 - AICPA Comments on Filing Relief for Natural Disasters Act (H.R. 2976)
The AICPA submitted a letter in support of H.R. 2976, the Filing Relief for Natural Disasters Act introduced by Representative Chu and Representative Katko and a letter in support of S. 1677, introduced by Senator Perdue and Senator Cortez Masto. We appreciate that the Act provides the IRS the authority to postpone federal tax deadlines by reason of state-declared disasters or emergencies.

May 28, 2019Comments on the OECD Public Consultation Addressing the Tax Challenges of the Digitalisation of the Economy
The Association of International Certified Professional Accountants (the Association) has submitted comments and recommendations to the Organization for Economic Co-operation and Development’s (OECD) public consultation on how to address the taxation of a global, digital economy. 

May 23, 2019AICPA Comments on the United States Senate Approval of Pending Income Tax Treaties and Protocols
The AICPA urges the Senate to approve the bilateral income tax treaties and protocols currently pending before them. The AICPA believes income tax treaties are vital to United States economic growth as well as U.S. trade and tax policy. Tax treaties are also important tools used to promote a competitive environment to attract foreign investment into the U.S. In order to serve their intended purpose, tax treaties must be kept up to date with developments in the global economy.

May 14, 2019AICPA Comment Letter On Notice 2018-99 - Parking Expenses for Qualified Transportation Fringes
The AICPA has provided comments and recommendations on the changes to section 274(a)(4) and the enactment of section 512(a)(7) in response to Notice 2018-99– Parking Expenses for Qualified Transportation Fringes. This letter is in response to the request by the IRS and Treasury for comments on the rules described in the Notice.

May 8, 2019 - AICPA Comments on Rev. Proc. 2018-31, List of Automatic Accounting Method Changes 
The AICPA has submitted recommendations with respect to Rev. Proc. 2018-31, which provides a list of accounting method changes for which automatic consent is granted. 

April 9, 2019AICPA Comments on 199A Safe Harbor and Final Regs
The AICPA submits comments on guidance concerning the deduction for qualified business income under section 199A in areas including: safe harbor for rental real estate, deemed trade or business for all commonly-owned arrangements, allocation based upon gross receipts, unadjusted basis immediately after acquisition on section 734(b) adjustments, and definition of qualified business income.

April 3, 2019 - AICPA Comments on Form 461 Instructions
The AICPA submitted our recommendation on the 2018 Instructions for Form 461, Limitation on Business Losses, dealing with application of the new loss limitation of section 461(l). 

March 28, 2019 - Traps for the Unwary: Tax Cuts and Jobs Act Changes
The AICPA has developed and published a listing of traps for the unwary from the Tax Cuts and Jobs Act changes. It identifies and details a list of 21 changes together with perhaps unexpected nuances, including the qualified business income section 199A changes and clarification issues discussed in further detail in Feb. 21, 2018Oct. 1, 2018, and April 9, 2019 AICPA comment letters to IRS on section 199A guidance.

March 26, 2019AICPA Comments on Proposed Foreign Tax Credit Regulations (REG-105600-18)
The AICPA has submitted comments to the IRS on proposed guidance related to the foreign tax credit. The recommendations focus on clarifications of the proper FTC basket to assign various categories of income and expenses as a result of changes made by the Tax Cuts and Jobs Act. 

March 20, 2019AICPA Recommendations for Tax Law Changes to Reflect How Small Businesses Operate in the Modern World
The AICPA has published a position paper that offers 13 recommendations for tax law changes to reflect how small businesses operate in the modern world. These recommendations simplify start-up phase tax rules, reduce operating costs, improve equity of how tax rules operate among business entity types and help the tax system to better meet principles of good tax policy. 

March, 1, 2019 - AICPA Comments to the Organization for Economic Cooperation and Development 
The Association of International Certified Professional Accountants has submitted comments to the Organization for Economic Cooperation and Development in response to a consultation paper on Addressing the Tax Challenges of the Digitalisation of the Economy.

February 28, 2019AICPA Comments on Sec 461(l) Limitations on Excess Business Losses
The AICPA acknowledges the IRS’s efforts in issuing Information Release 2018-254 (IR-2018-254) and draft instructions for the 2018 Form 461. However, we request the issuance of much-needed substantial guidance for 461(l) in areas including: operating principles, definitions related to business income, definitions related to business deductions and losses, treatment of gains and losses, treatment of qualified plans, treatment of industry specific issues, and application to trusts and estates.

February 27, 2019 - Association Response: HM Treasury Digital Services Tax Consultation
The Association of International Certified Professional Accountants has submitted comments to the UK government in response to a consultation paper on a proposed Digital Services Tax.

February 21, 2019 - AICPA comments on section 163(j) proposed regulations
The AICPA submits their recommendations and observations on the proposed regulations regarding the business interest expense limitation. 

February 19, 2019AICPA Comments on the Taxpayer Penalty Protection Act of 2019 (H.R. 1300)
The AICPA supports the Taxpayer Penalty Protection Act of 2019 (H.R. 1300) and commends the efforts to assist taxpayers as they deal with numerous and challenging changes resulting from Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).

February 15, 2019 - AICPA Comments on Proposed Regulations Regarding Estate and Gift Taxes and the Difference in the Basic Exclusion Amount
AICPA comments on the proposed regulations (REG-106706-18) regarding the increased basic exclusion amount for estate and gift taxes. 

February 13, 2019 - AICPA Comments on Small Business Relief from Definition of Tax Shelter
AICPA requests that Treasury and the IRS provide certain small businesses relief from the definition of a tax shelter to ensure that they will qualify for the small business simplifying provisions available under Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).

January 28, 2019 - AICPA Comments on the Penalty Relief Needed for Taxpayers for 2018 Filing Season
The AICPA urges Treasury and the IRS to provide additional and more extensive underpayment and late payment penalty relief to taxpayers who are unable to adjust their withholding and estimated tax payments for the 2018 tax year due to the changes resulting from Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA).

January 24, 2019AICPA Letter on Effect on Taxpayers and Tax Practitioners of the Shutdown of the Internal Revenue Service
The AICPA recognizes the inherent and systemic limitations, both Treasury and the IRS face during the shutdown. Our members have expressed concerns regarding the effect of the shutdown of the Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) on taxpayers and tax practitioners. 

January 24, 2019AICPA Proposed Regulations on Investing in Qualified Opportunity Zones (REG-115420-18)
The AICPA has submitted comments and recommendations to the IRS related to the proposed regulations on Investing in Qualified Opportunity Zones (REG-115420-18) which provide guidance on the deferral of gains resulting from a taxpayer’s investment in a Qualified Opportunity Fund.

January 10, 2019 - AICPA Comments on Proposed Guidance Related to Section 951A (Global Intangible Low-Taxed Income) (REG-104390-18)
The AICPA has submitted comments to the IRS on proposed regulations under section 951A of the Tax Cuts and Jobs Act (a/ka/ the GILTI regime). The recommendations focused on carryforward of net tested losses, several proposed anti-abuse provisions and the interaction with the section 245A Dividends Received Deduction.

January 9, 2019 - AICPA Comments on the Relief from Sections 6654 and 6655 Penalties for Specified Taxpayers
The AICPA has requested Treasury the IRS provide relief for estimated tax penalties imposed under section 6654 and 6655 for any taxpayer subject to the provisions of section 965 as enacted by the Tax Cuts and Jobs Act (TCJA).

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