2020 Tax Advocacy Comment Letters

January 10, 2020 Modified: March 11, 2020

March 26, 2020 - AICPA Comment Letter for the Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic
The AICPA respectfully submits our comments on relief for taxpayers affected by the ongoing Coronavirus Disease 2019 (COVID-19) pandemic. Specifically, we request that all Federal income tax, information returns, and payments originally due between March 3, 2020 and July 15, 2020 are granted additional time to file and pay until July 15, 2020.

March 19, 2020 - AICPA Letter of Support for Tax Filing Relief for America Act
The AICPA urges Congress to include the Tax Filing Relief for America Act recently introduced by Senator Thune in the Phase III stimulus bill. This is important legislation that will provide tax filing relief for taxpayers affected by the ongoing Coronavirus Disease 2019 (COVID-19) pandemic. Tasks that are required of taxpayers (e.g., contributing to retirement plans and making elections) and those of tax preparers and taxpayers (e.g., determining taxable income and tax liability for a valid extension) should not be required prior to July 15, 2020. No income tax or other returns should be due before July 15, 2020.

March 11, 2020 - AICPA Comments on BEAT Regulations
The AICPA submits our comments on the notice of proposed rulemaking for additional rules regarding base erosion and anti-abuse tax (BEAT) [REG-112607-19] and final regulations [T.D. 9885]. Specifically, our recommendations address the change in the aggregate group, the election to waive deductions, the request for automatic relief on 2018 returns, and the application of qualified derivative payments (QDPs).

March 4, 2020AICPA Comments on Section 199A
The AICPA submits comments on two priority member issues regarding section 199A. Specifically, we recommend that Treasury and the IRS confirm that various self-employed deductions under sections 164(f), 162(l), and 404 are not automatically reductions of QBI, and update form instructions to reflect the same treatment for a charitable deduction under section 170.

March 2, 2020AICPA Comment Letter on The Freedom to Invest in Tomorrow’s Workforce Act (H.R. 5339)
The AICPA supports the bipartisan legislation, H.R. 5339, the Freedom to Invest in Tomorrow’s Workforce Act. This bill would expand eligible uses of 529 savings plans to include fees and expenses required to obtain or maintain a recognized postsecondary credential, including professional credentials and certifications. It is our understanding that this provision would allow individuals to use 529 funds for expenses, fees, and costs related to the Uniform CPA Examination, which is one of three critical components required for licensure as a CPA in the United States.

February 28, 2020 - AICPA Comments on IRS Virtual Currency Guidance
The AICPA submits our comments on Revenue Ruling 2019-24, the new question on Schedule 1 (Form 1040), and the Internal Revenue Service’s frequently asked questions on virtual currency transactions. Virtual currency transactions, in which taxpayers increasingly engage, add a new layer of complexity to the analysis of a client’s reporting requirements. The issuance of additional guidance will provide certainty and clarity to tax preparers and taxpayers on the application of the tax law to virtual currency transactions.

February 27, 2020AICPA Written Statement for Hearing on Wayfair Small Business Impact and AICPA Oral Testimony at the hearing
AICPA submitted the written statement and oral statement for the March 3, 2020 hearing of the House Small Business Committee Subcommittee on Economic Growth, Tax and Capital Access on the impact of the Wayfair decision on small businesses.

February 26, 2020 - AICPA Additional Comments on Proposed Regulations Concerning Eligible Terminated S Corporations under Section 1371(f) (REG–131071–18)
The AICPA is submitting additional comments pertaining to the proposed regulations under sections 1371(e) and (f) regarding the post-termination transition period (PTTP) provided for in those proposed regulations.

February 19, 2020AICPA Comments on Notice 2019-09
The AICPA has submitted recommendations on Notice 2019-09 - Interim Guidance on Excise Tax Imposed under Section 4960, Excess Remuneration.

January 30, 2020AICPA Recommendations for Taxpayer First Act – Tax Professionals’ Feedback
The AICPA has participated in a group of 10 stakeholder organizations to provide the IRS with recommendations as it prepares reports to Congress as mandated by the Taxpayer First Act. The letter outlines recommendations for providing taxpayers access to empowered IRS employees, timely information and tailored resources; placing greater emphasis on customer-focused employee training; and improving the technological and organizational infrastructure.

January 8, 2020 - AICPA Comments on Notice 2019-66 on At-Risk Activities Reporting for S Corporations
AICPA submitted comments to Treasury and the IRS on Notice 2019 and a request for similar section 465 at-risk activities reporting relief for S corporations as provided for partnerships.

Tax Policy & Advocacy letters, testimony and related documents for 2013201420152016, 2017, 2018 and 2019.