Recommendations for IRS Priority Guidance Plan

Jun 21st 2018
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The American Institute of CPAs (AICPA) has sent the IRS more than 150 recommendations in response to the agency’s 2018-2019 Priority Guidance Plan.

It likely comes as no surprise to tax preparers and CPAs that, except for one of the 11 AICPA panels that weighed in on the recommendations, the Tax Cuts and Jobs Act (TCJA) has top priority among the issues raised in the 24-page letter. (The Tax Practice Responsibilities Committee’s six points didn’t mention the TCJA but instead addresses issues regarding tax shelters, reasonable cause, preparer penalties, PATH Act changes and tax credits, signature authority, and issues and corrections regarding Sections 6662, 6664 and 6694.

Other recommendations include a broad range of tax issues affecting individuals, businesses and exempt organizations. Those issues concern international, partnership, crowdfunding and the sharing economy; virtual currency, and estate and trust rules.

The AICPA also “encourages” the IRS and Treasury to simplify taxation, wrote attorney Annette Nellen, CPA, CGMA, chair of the organization’s Tax Executive Committee. Part of the agencies’ guidance process also should include the simplest approach to a policy goal, provide safe harbor alternatives, provide clear and consistent definitions, use horizontal drafting (a rule placed in one IRS section should apply to all other code sections), build on existing business and industry-standard record-keeping practices, balance simple general rules with more complex detailed rules, and match a rule’s complexity to the sophistication of the targeted taxpayers, Nellen wrote.

According to the IRS’ 2018-43 notice in the second link above, the agency notes that it and Treasury will prioritize guidance projects to be worked on from July 1 through June 30, 2019. Not surprisingly, the two agencies expect to concentrate on the TCJA and won’t complete some of the projects in last year’s guidance plan.

Those projects will be carried over to the latest plan. Three addresses are provided in the IRS notice for comments, including standard and electronic mail, and hand delivery.

Comments or questions to the AICPA can be emailed to Nellen or AICPA Senior Manager of Tax Policy and Advocacy Melanie Lauridsen at addresses in the letter. Phone numbers also are provided.

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