Tax Policy & Advocacy letters, testimony and related documents for 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023 and 2024.
September 4, 2025 - The Association Submits Comments to OECD on Pillar 2 Co-Existing with U.S. Tax Rules
The Association has submitted comments on Pillar 2 co-existing with the U.S. Tax Rules in a side-by-side system to the OECD. The letter provides recommendations on the timing of the guidance as well as on substance-based non-refundable tax credits, such as U.S.’s section 41 research credit.
July 31, 2025 - AICPA Sends Comment Letter Asking for Guidance on Section 174A
The AICPA sent a letter to both the IRS and Treasury on the recently enacted section 174A related to domestic research and experimental expenditures. The letter recommends immediate guidance to provide the ability for eligible small business taxpayers to immediately deduct, on their 2024 originally filed income tax returns, domestic research costs paid or incurred in taxable years beginning in 2024.
July 28, 2025 - AICPA Sends Letter of Support for S. 2129, the
In a letter sent to Senator John Fetterman (D - PA), the AICPA commended the introduction of legislation that would provide an option for taxpayers experiencing spousal abuse or abandonment.
July 23, 2025 - AICPA Submits Comments on Modifications to the IRS Direct Pay for Exempt Organizations Comment Letter
The AICPA submitted a comment letter to the IRS citing needed modifications to the IRS Direct Pay system for exempt organizations, specifically regarding its payments associate with Form 990-T, Form 990-T, Form 4720 and Form 1120-POL.
July 15, 2025 - AICPA Supports H.R. 3975, Tax Fairness for Disaster Victims Act
The AICPA sent a letter to Representative Timothy Kennedy (D – New York) to express support for his introduction of H.R. 3975, the Tax Fairness for Disaster Victims Act. The legislation would allow individuals impacted by federally declared disasters to elect the prior year’s earned income for purposes of the Earned Income Tax Credit (EITC).
July 11, 2025 - AICPA Comments on Corporation Reorganizations and Separations Proposed Regulations
AICPA submitted to IRS recommendations on proposed regulations regarding certain matters related to nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations (REG-112261-24), and multi-year reporting requirements for corporate separations and related transactions (REG-116085-23).
July 11, 2025 - Taxpayer Victory – Natural Disasters Act to Deliver Rapid Relief and Certainty, Headed to President’s Desk for Signature
Congress has passed the Filing Relief for Natural Disasters Act (H.R. 517), which the AICPA and state CPA societies have strongly supported and advocated Congress to authorize the Internal Revenue Service (IRS) to postpone federal tax deadlines for taxpayers affected by a qualified state-declared disaster upon a declaration by the state governor. Earlier this year, the House of Representatives unanimously passed the H.R. 517, and on July 11, the Senate passed the bill by unanimous consent.
July 1, 2025 - AICPA Comments on Proposed Regulations to Section 603 of SECURE 2.0 Act
The AICPA made recommendations to Treasury and the IRS on their proposed regulations to implement a SECURE 2.0 provision which requires that catch-up contributions made to retirement plans by certain eligible participants must be designated as Roth contributions.
June 30, 2025 - AICPA Makes Recommendations as Treasury and IRS Transition to Electronic Payment and Disbursement System
The AICPA submitted recommendations to consider automatic exceptions for certain taxpayers that may be unable or unwilling to comply with Executive Order 14247, to delay implementation until Treasury and the IRS have resolved various electronic payment issues and updated various tax forms, and to partner with stakeholders (e.g., AICPA) in developing processes, exploring solutions, and implementing rules.
June 28, 2025 - AICPA Letter on the OBBB Senate Substitute Amendment
The AICPA expressed strong support of tax-related provisions included in the latest version of the OBBB that the Senate plans to consider in the coming days.
June 23, 2025 - AICPA Comment Letter Recommends Changes to PTET Tax Provisions in Senate Finance Committee’s Reconciliation Bill
In a letter sent to both the Senate Committee on Finance (SCF) and the House Committee on Ways and Means, the AICPA provided comments regarding the SCF’s proposed reconciliation bill text and expressed concern over the disparity in tax treatment that would result from limiting the state and local tax deduction for pass-through entities.
June 17, 2025 - AICPA Submits Recommendations on Revenue Ruling 2025-4
The AICPA submitted recommendations on Revenue Ruling 2025-4 related to the federal income and employment tax treatment of contributions and benefits paid in certain situations under state-paid family and medical leave statute.
June 16, 2025 - AICPA Comments to MTC on Draft White Paper on Sourcing Partnership Income
The AICPA submitted comments to the Multistate Tax Commission (MTC) on their draft white paper on sourcing of partnership income.
June 16, 2025 - AICPA Updated Comments to IRS on Form 706, US Estate (and GST) Tax Return and Schedule R-1 (Form 706) and Instructions
The AICPA submitted comments to IRS in response to a request for comments in OMB Control Number 1545-0015 – Public Comment Request Notice - Regarding Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, and Schedule R-1 (Form 706) (dated April 2, 2025).
June 6, 2025 - AICPA and State CPA Society PTET Letter
The AICPA and state CPA societies in 53 states and jurisdictions sent a letter to the Senate Committee on Finance urging the retention of the ability for all pass-through entities to deduct state and local taxes at the entity level.
June 5, 2025 - AICPA Comments on 2025-2026 IRS Priority Guidance Plan
The AICPA submitted to IRS comments on the 2025-2026 IRS Priority Guidance Plan (Notice 2025-19), listing 183 items of suggested and needed guidance.
May 29, 2025 - AICPA Submits Comment Letter to Senate on the One Big Beautiful Bill Act
The AICPA provided comments to the Senate as they consider the various proposals in the House passed One Big Beautiful Bill Act
May 20, 2025 - AICPA Submits Comment Letter on PTET Deduction in the One Big Beautiful Bill Act
The AICPA sent a letter expressing opposition to the elimination of the pass-through entity tax deduction in the One Big Beautiful Bill Act.
May 20, 2025 - AICPA Submits Comment Letter on the One Big Beautiful Bill Act
In a letter sent to leadership of the Senate Finance and House Ways & Means Committees, the American Institute of CPAs (AICPA) addressed concerns the group has with several tax proposals impacting the accounting profession in the One Big Beautiful Bill Act, which was advanced by the House Ways & Means Committee on May 14, 2025.
May 16, 2025 - CPAs Visit Capitol Hill to Discuss Key Accounting Profession Concerns During AICPA’s Annual Spring Council and Members Meetings
AICPA issued a press statement on CPAs met with members of Congress to thank them for their support of recent disaster tax relief legislation and encourage their support of four key issues: legislation to establish the accounting profession as a STEM career pathway; legislation to expand 529 plans to include postsecondary credentials, granting financial flexibility to those pursuing or advancing in the accounting profession; the pass-through entity tax (PTET) deduction, which is an IRS-approved approach aimed at providing fairness for all types of businesses; and the Guiding Principles of Good Tax Policy, which outline a framework on appropriate standards to ensure an effective tax system based on good tax policy.
May 14, 2025 - AICPA Comment Letter of Support for Tax Relief for Victims of Crimes, Scams and Disasters Act
The AICPA submitted a letter in support of the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S. 1773), which would repeal the suspension of personal casualty loss deductions not attributable to a federally declared disaster.
May 14, 2025 - AICPA Submits Comments on PTEP Proposed Regulations
The AICPA provided comments to the Treasury and IRS regarding REG-105479-18 – Proposed Regulations Regarding the Previously Taxed Earnings and Profits and Related Basis Adjustments under Sections 959 and 961.
May 13, 2025 - AICPA Responds to House Ways and Means Committee Release of Tax Reform Legislation
AICPA issued a press statement on the House Ways and Means Committee release of tax reform legislation.
May 6, 2025 - AICPA Provides Comments to Treasury and the IRS in Response to Section 162(m) Proposed Regulations
The AICPA's comment letter provided comments and recommendations related to proposed regulations for certain employee remuneration in excess of $1,000,000 under Internal Revenue Code Section 162(m) [REG 118988-22].
April 30, 2025 - AICPA Submits Recommendations on Updated Instructions to Form 8971
In a letter to the Department of the Treasury and the IRS, the AICPA made recommendations for updated instructions to the Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent, to ensure clarity and compliance. The current instructions to the Form 8971, were last revised January 2016.
April 24, 2025 - AICPA Comments on Notice 2025-04 Application of the Simplified and Streamlined Approach Under Section 482
The AICPA sent a letter to both the IRS and Treasury in response to Notice 2025-04 requesting guidance on certain aspects of applying the OECD’s simplified and streamlined approach (SSA) as a new transfer pricing method under the section 482 regulations for pricing of baseline marketing and distribution activities. The SSA is described in the OECD’s report on Pillar One Amount B.
April 14, 2025 - AICPA Support of Alabama H.B. 379, as Amended, the Alabama Workforce Bill
The AICPA submitted a letter supporting Alabama H.B. 379, as amended, which would provide a 30-day threshold before nonresident employees working in Alabama are subject to Alabama’s income tax and withholding, plus exclude workers who are working temporarily in Alabama on officially declared disaster relief projects.
April 11, 2025 - AICPA Support of S. 1443, the Mobile Workforce State Income Tax Simplification Act of 2025
In a letter to Senate Majority Leader Thune and Senator Cortez Masto, the AICPA expressed support for the Mobile Workforce State Income Tax Simplification Act (S. 1443), citing the Act's balance between the states’ rights to tax income from work performed within their borders, and the needs of individuals and businesses, and especially small businesses, to operate efficiently. The AICPA also issued a press release detailing its support for the bill’s introduction, while Sen. Thune issued a press release mentioning AICPA's support for the legislation.
April 2, 2025 - AICPA Comments on Section 2642(g) Final Regulations, Relief Provisions Respecting Timely Allocation of GST Exemption and Certain GST Election
AICPA submitted comments on the section 2642(g) final regulations (Treas. Reg. § 26.2642-7), which provide relief provisions respecting timely allocation of GST exemption and certain GST elections. AICPA suggested Treasury and IRS extend the relief provided by Rev. Proc. 2004-46 to tax years 2001 and later, and suggested a simplified procedure for obtaining an extension of time to elect out of automatic allocation of GST exemption to indirect skips, similar to Rev. Proc. 2004-46.
April 1, 2025 - AICPA Applauds Passage of Bipartisan Bills to Improve Tax Administration and Offer Relief to Taxpayers, Practitioners
The AICPA applauded the unanimous passage in the House of 4 bills that AICPA recently submitted a support letter on H.R. 1152, the Electronic Filing and Payment Fairness Act, H.R. 998, the Internal Revenue Service Math and Taxpayer Help Act, H.R. 517, the Filing Relief for Natural Disasters Act (FRNDA), and H.R. 1491, the Disaster Related Extension of Deadlines Act (DREDA).
March 31, 2025 - AICPA Comment Letter Support of H.R. 1152, H.R. 998, H.R. 517 and H.R. 1491
In a letter to the House of Representatives, the AICPA expressed support for H.R. 1152, the Electronic Filing and Payment Fairness Act, H.R. 998, the Internal Revenue Service Math and Taxpayer Help Act, H.R. 517, the Filing Relief for Natural Disasters Act (FRNDA), and H.R. 1491, the Disaster Related Extension of Deadlines Act (DREDA).
March 19, 2025 - AICPA Comment Letter on Proposed Regulations Related to Automatic Enrollment Requirements Under Section 414A
The AICPA's comment letter addresses proposed regulations [REG-100669-24] implementing the automatic enrollment provisions authorized under SECURE 2.0 and codified in section 414A. This letter specifically refers to investment requirements for Trustee Direct Plans, determining employee count for small businesses and definition of predecessor employer.
March 7, 2025 - AICPA Press Statement on IRS Services for this Tax Season
AICPA provided a press statement on IRS services for this tax season. The ability of the IRS to maintain service levels for taxpayers and their preparers is critically important to the AICPA. IRS services in combination with modernization efforts, which include technology advancements, have been the bedrock of AICPA’s recommendations for many years. A modern, functioning IRS is essential for Americans to meet their tax obligations and to our country’s financial health.
March 6, 2025 – 2025 AICPA Tax Legislation Priorities and 2025 Tax Legislative Compendium
AICPA submitted to Congress its 2025 AICPA tax legislation priorities and a list of AICPA-endorsed tax bills introduced in the 119th and 118th Congress, our guiding principles of good tax policy, and our 2025 Tax Legislative Compendium, which contains 69 proposals that are non-controversial simplification and technical changes to provisions in the Internal Revenue Code that need attention and recommendations that perhaps can be readily addressed.
March 6, 2025 – AICPA Press Statement on BOI Enforcement Freeze and Anticipation of Clarification
AICPA released a statement on the BOI enforcement freeze for domestic entities and U.S. citizens and anticipates clarification and urged Treasury to, at a minimum, extend the filing deadline through January 1, 2026, for all businesses. AICPA noted that beneficial owners of foreign-owned companies operating in the United States may still be expected to file.
March 3, 2025 - AICPA Submits Comment Letter Citing the Need for Permanent, Consistent, and Clear Disaster Relief Tax Legislation
The AICPA submitted a letter to members of the House Ways and Means and Senate Finance Committees citing the need for legislative efforts providing permanent, consistent, and clear tax relief to individuals and businesses affected by natural disasters.
March 3, 2025 - AICPA Comment Letter Seeks Clarification on Qualified Student Loan Payment Matching Contribution Deadline
The AICPA recommends that Treasury and the IRS issue proposed regulations stating that any qualified student loan payment match claim deadline as early as one month after the end of the plan year is presumed to be reasonable for purposes of SECURE 2.0 Section 110.
February 25, 2025 - AICPA Letter of Support for H.R. 517 and H.R. 1491
The AICPA endorses and supports the Filing Relief for Natural Disasters Act (FRNDA) (H.R. 517) and the Disaster Related Extensions of Deadlines Act (DREDA) (H.R. 1491). The AICPA supports and appreciates the effectiveness, efficiency, and clarity that the FRNDA and the DREDA would afford to taxpayers and tax practitioners following the hardships and distress ushered in by natural disasters.
February 25, 2025 - AICPA Written Testimony to House Ways and Means Subcommittee on Oversight for Hearing on “IRS Return on Investment and the Need for Modernization”
The AICPA provided written testimony to the Subcommittee on Oversight to address the need for the Internal Revenue Service (IRS) to continue to improve its modernization efforts. The AICPA advised the IRS to continue those efforts and update its antiquated technology infrastructure, employ tax professionals to address the lack of guidance on technical issues, and streamline the taxpayer’s and tax professional’s ability to communicate with the IRS in a timely and effective manner.
February 21, 2025 - AICPA Comments on Treasury and IRS Final Regulations Addressing Certain Basis-Shifting Transactions Involving Partnerships and Related Parties
The AICPA stated that the final regulations exceed its intended scope by including real, substantive transactions, that would be considered reportable transactions, causing undue hardship to taxpayers, especially due to the retroactive nature of the proposed rules. The recommendation is to have the final regulations suspended and then removed.
February 19, 2025 – AICPA Comments on Proposed Regulations on Circular 230, Request to Testify at 3/6/2025 Hearing and Oral Testimony
The AICPA submitted comments to the IRS on proposed regulations on Circular 230 (REG-116610-20) and a request to testify at the public hearing on the Circular 230 proposed regulations. An AICPA member delivered oral testimony to the IRS during a March 6, 2025 hearing.
February 18, 2025 - AICPA Recommends Modification to Draft Publication 547, Casualties, Disasters, and Thefts
The AICPA recommends modifying Draft Publication 547, Casualties, Disasters, and Thefts, to clarify the qualified disaster loss requirements under the Federal Disaster Tax Relief Act of 2023 (FDTRA). Specifically, any mention of the FDTRA should provide all qualified disaster loss requirements to avoid confusion regarding the deadlines for federally declared disasters and incident periods.
February 16, 2025 - AICPA Releases Statement on IRS Ability to Help Taxpayers Meet Filing Obligations
AICPA issued a statement on IRS ability to help taxpayers meet filing obligations.
February 13, 2025 - AICPA Recommendation to Amend Qualified Business Income Deduction
AICPA sent a letter recommending that Congress broaden the QBI deduction by increasing the $50,000 (non-joint returns) and $100,000 (joint returns) amounts under section 199A(b)(3)(B) and section 199A(d)(3)(A), which will prevent taxpayers within the phase-in range from experiencing significant reductions of the QBI deduction for exceeding the SSTB threshold amounts.
February 12, 2025 - AICPA Press Statement on House Ways and Means Committee Approval of AICPA Endorsed Bipartisan Legislation on an Electronic Filing Mailbox Rule and Math Corrections Transparency
AICPA issued a press statement on the House Ways and Means Committee approval of AICPA endorsed bipartisan legislation on an electronic filing mailbox rule, H.R. 1152, the Electronic Filing and Payment Fairness Act, and a bill to provide transparency regarding math corrections, H.R. 998, the Internal Revenue Service Math and Taxpayer Help Act.
February 12, 2025 - AICPA Letter of Support for H.R. 1152, the Electronic Filing and Payment Fairness Act, and H.R. 998, the Internal Revenue Service Math and Taxpayer Help Act
In a letter to the U.S. House Ways and Means Committee, the AICPA expressed support AICPA endorsed bipartisan legislation on an electronic filing mailbox rule, H.R. 1152, the Electronic Filing and Payment Fairness Act, and a bill to provide transparency regarding math corrections, H.R. 998, the Internal Revenue Service Math and Taxpayer Help Act.
January 31. 2025 - AICPA Comments on Form 709 and Instructions
In response to OMB Control 1545-0020 request for comments, AICPA submitted to IRS 24 updated suggestions for improvements to the 2024 draft Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, (dated September 12, 2024) and updated instructions (dated November 14, 2024), as well as guidance and regulations updates if Treasury and IRS find that the issues are beyond changes to the form and instructions.
January 30, 2025 - AICPA Recommends Improvement to Tax Forms for Taxpayers Affected by Disaster
The AICPA requests that the IRS consider include a checkbox and space for a FEMA declaration number to allow taxpayers affected by federally declared disasters to self-identify as eligible for disaster relief. A checkbox and FEMA declaration number space would supplement the current process of self-identifying via IRS’s telephone services and would serve as a backup to the IRS’s current automated process of identifying taxpayers eligible for disaster relief.
January 30, 2025 - AICPA Expresses Strong Support for Bipartisan Discussion Draft to Improve IRS Administration
AICPA applauded the release of the bipartisan Crapo-Wyden Taxpayer Assistance and Service (TAS) Act discussion draft, containing 13 tax administration provisions that AICPA supported and endorsed, and a total of 65 provisions to meaningfully reduce the burdens on taxpayers and their preparers.
January 27, 2025 - AICPA Recommends Providing Tax-Exempt Organizations Filing Relief for Certain Foreign-Related Filings
The AICPA recommends that Treasury and the IRS consider providing to certain tax-exempt organizations filing relief for Form 926, Form 8865, and Form 5471. Often, tax-exempt organizations investing in these foreign entities have relatively small interests therein, but may have dozens of such small investments, which generates a significant tax administrative burden for filing these forms.
January 21, 2025 - AICPA Offers Strong Support for H.R. 517, Bipartisan, Bicameral Legislation Postponing Federal Tax Deadlines for State-Declared Disasters
AICPA supports legislation introduced by Representatives David Kustoff (R-TN) and Judy Chu (D-CA) in the House (H.R.517) and Senators Catherine Cortez Masto (D-NV), John Kennedy (R-LA), Chris Van Hollen (D-MD) and Marsha Blackburn (R-TN) in the Senate would amend the Internal Revenue Code (IRC) to allow state-declared disasters to trigger a postponement of certain filing and payment deadlines, at the discretion of the IRS.
January 15, 2025 - AICPA Recommendations on Corporate Alternative Minimum Tax (CAMT)
The AICPA sent a letter to both the IRS and Treasury which included comments and recommendations providing additional information regarding CAMT guidance provided in the proposed regulations. These most recent comments follow previously submitted letters to Congress in 2021 and 2022 requesting immediate guidance on the CAMT rules.
January 12, 2025 - AICPA State Position Paper and Guide on State Disaster Tax Relief
The AICPA has developed a position paper and guide on state disaster tax relief, that includes a state-by-state analysis and map on states’ disaster tax relief enacted legislation and binding regulations to allow automatic one additional month state filing disaster relief following IRS federal disaster tax relief deadlines.
January 7, 2025 - AICPA Recommendations on Proposed Texas Administrative Code on Data Processing Services
In a letter to the Texas Comptroller of Public Accounts, AICPA recommended that the proposed rule amendments to Texas Administrative Code (TAC), Title 34, Part 1, Chapter 3, Subchapter O, Rule § 3.330(a)(1) (dated Aug. 30, 2024), be modified to include and not delete the current rule exception for tax return preparation and all financial statements preparation in the definition of “data processing services."
January 2, 2025 - PFP Division Advocacy Positions
A group of passionate AICPA member volunteers came together with staff, council members, and the board of directors to form the Personal Financial Planning (PFP) Division for the purpose of representing and giving voice to CPAs providing personal financial planning services (i.e., tax, retirement, estate, investment, and risk management planning for individuals and families).