The American Institute of CPAs (AICPA) has asked the US Department of the Treasury and Internal Revenue Service (IRS) for guidance on the newly enacted H.R. 1, (the One Big Beautiful Bill Act).
In a letter, the AICPA sought clarification on how individuals, estates and trusts should report income taxes under H.R. 1.
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The letter focused on Section 70111, which revises the Section 68 cap on itemised deductions.
It also referenced Notice 2025‑68, where the IRS planned regulations for Section 530A Trump accounts, including proposed guidance on gift tax reporting.
AICPA Tax Policy & Advocacy director Eileen Sherr said: “The lack of detailed guidance in these areas creates uncertainty as well as operational and compliance challenges.”
The organisation is seeking clarification on how the Section 68 limitation should be calculated for taxpayers whose taxable income exceeds the 37% tax rate starting threshold.
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By GlobalDataIt also wants direction on how this limitation applies to estates’ and trusts’ charitable deductions, income in respect of a decedent, section 642 deductions, income distribution deductions and certain administration expenses.
Additionally, the AICPA is asking for a clear definition of adjusted gross income under section 67 as it relates to these entities and deductions.
On Notice 2025‑28 and Section 530A Trump accounts, the request covers how contributions should be treated for gift and generation-skipping transfer tax purposes.
The institute is also asking for rules on how excess contributions to a Trump account should be returned and how associated gains or losses should be allocated.
Further clarification is sought on the penalty of perjury for authorised individuals opening Trump accounts on behalf of eligible persons, along with how priority listing mechanics are intended to function.
The AICPA also wants more detail on automatic enrolment of eligible individuals, including how a federal pilot programme would operate.
Additionally, the letter asks for guidance on the use of Form 8879‑TA for electronically filed tax returns connected to Trump accounts, the process for designating a new responsible party after an account is opened and the criteria for determining whether an index is primarily made up of US equity investments.
