2019 Tax Advocacy Comment Letters

January 8, 2019 Modified: February 21, 2019

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 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).

Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016, 2017 and 2018.