The American Institute of CPAs (AICPA) submitted a letter to the Internal Revenue Service (IRS) containing 182 suggestions regarding the 2023-2024 Guidance Priority List. As the IRS plans to prioritise providing additional guidance as stated in the IRS Strategic Operating Plan, the AICPA encourages the IRS to issue guidance on recommended areas.

In addition, the AICPA encouraged the Department of the Treasury and the IRS to continue pursuing tax simplification, recognising the balance needed for competing interests and concerns when drafting guidance. The AICPA urged the following as part of the process:

Use the simplest approach to accomplish a policy goal;

  • Provide safe harbour alternatives;
  • Offer clear and consistent definitions;
  • Use horizontal drafting (a rule placed in one Internal Revenue Code section should apply in all other Code sections) to the greatest extent possible;
  • Build on existing business and industry-standard record-keeping practices;
  • Provide a balance between simple general rules and more complex detailed rules; and
  • Match a rule’s complexity to the sophistication of the targeted taxpayers.

The AICPA’s recommendations come from the organisation’s Taxation Technical Resource Panels, which cover the following areas: Corporations and Shareholders; Employee Benefits; Exempt Organisations; Individual and Self-Employed; International; IRS Advocacy & Relations; Partnership; S Corporation; Tax Methods and Periods; Tax Practice Responsibilities; and Trust, Estate and Gift Tax.

AICPA’s director of tax policy and advocacy, Eileen Sherr, said: “The items are listed in priority order in each area, so we encourage Treasury and IRS to prioritise guidance for the top items in each area.”

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