Tax Policy & Advocacy letters, testimony and related documents for 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 and 2025.
May 21, 2026 - AICPA Comment Letter on MTC Sourcing of Partnership Income Combined Draft Model Provisions and Recommendations
In a letter submitted to the Multistate Tax Commission (MTC), the AICPA provides comments on the sourcing of partnership income combined draft model provisions & recommendations (“model provisions”). The model provisions are part of the MTC’s landmark Project on the State Taxation of Partnerships.
May 19, 2026 - AICPA Submits Comments Requesting Relief for Taxpayers Using the IPIC Computation Method for LIFO Inventory
In a letter submitted to the Treasury and Internal Revenue Service (IRS), the AICPA asked for guidance providing automatic consent procedures to allow taxpayers to change from the inventory price index computation (IPIC) method to an internal index method if one or more Producer Price Index (PPI) categories that was previously used was discontinued.
May 15, 2026 - AICPA Expresses Support for HR 425
Rep. Warren Davidson (R - OH) received a letter of support from the AICPA introduction of H.R. 425, the Repealing Big Brother Overreach Act, which, as introduced, would repeal the Corporate Transparency Act and the amendments made by that legislation. The bill recognizes the broad compliance burden created by the BOI reporting regime and the need for Congress to reassess whether the rule's scope is appropriately tailored to
the U.S. government’s anti-money laundering objectives.
May 15, 2026 - AICPA Sends Letter to Senators in Support of S. 4419
The AICPA sent a letter to Senators John Kennedy (R - LA) and Mike Lee (R - UT) in support of S. 4419 which would make permanent a Treasury rule limiting FinCEN’s BOI reporting to foreign beneficial owners, helping reduce unnecessary burdens on U.S. businesses, small business owners, and financial professionals who support them.
May 13, 2026 - AICPA Submits Comments on IRS 2026-2027 Priority Guidance Plan
The AICPA submitted comments to the Internal Revenue Service (IRS) containing 193 recommendations regarding the 2026-2027 Priority Guidance Plan. The AICPA’s recommendations span the organization’s ten technical resource panels.
May 1, 2026 - AICPA Letter Urges IRS to Issue Guidance for Section 4960, Transition Relief
The AICPA's comment letter to Treasury and the IRS requests guidance addressing transition relief for fiscal year filers, extension of the limited hours, the nonexempt funds exception and the limited services, and a regulatory exception for unpaid public volunteers from being treated as “covered employees".
April 22, 2026 – AICPA Provides Feedback on the IRS 2026 Filing Season
The AICPA’s comment letter to the Senate Finance Committee leadership addressed the IRS’s performance during the 2026 filing season and provided recommendations on IRS taxpayer services, IRS practitioner services, and IRS oversight to improve future filing seasons.
March 13, 2026 - AICPA Sends Comments and Recommendations on Section 45S - Paid Family and Medical Leave Credit
The AICPA requests guidance from the Treasury and IRS on how employers should implement the changes to section 45S by the OBBBA, which took effect on January 1, 2026. Due to changes to section 45S, a broader group of employers will be eligible to claim the paid family and medical leave credit.
March 5, 2026 - AICPA Recommends IRS Expand and Adjust First Time Abatement Program
The AICPA submitted a comment letter to the IRS making recommendations to expand the first time abatement (FTA) program to additional tax and information returns and to allow taxpayers to substitute reasonable cause for automatically applied FTA relief. The IRS intends to automatically apply FTA relief for taxpayers when applicable; however, the AICPA recommends that IRS allow taxpayers to reverse FTA relief for valid reasonable cause statements, which would preserve taxpayers’ FTA relief for a later date. The recommendations would alleviate significant tax administrative burdens on the IRS, increase taxpayer awareness of the availability of FTA relief, and promote voluntary taxpayer compliance.
March 4, 2026 - AICPA Sends Letter of Support for H.R. 7026, the Fiscal State of the Nation Act
The AICPA sent a letter to Congressman Andy Barr and Congressman Scott Peters in support of H.R. 7026, the Fiscal State of the Nation Act. The legislation would provide a "joint hearing of the Committees on the Budget of the House of Representatives and the Senate to receive a presentation from the Comptroller General of the United States regarding the audited financial statement of the executive branch."
March 2, 2026 - AICPA Expresses Strong Support for Bipartisan Bill to Improve IRS Administration
AICPA signaled its strong support for the Taxpayer Assistance and Service (TAS) Act, a bipartisan bill that contains 63 provisions designed to improve tax administration and reduce the burdens on taxpayers and their preparers. The bill was introduced by Senate Finance Committee Chairman Mike Crapo (R-ID) and Ranking Member Ron Wyden (D-OR), and it addresses important tax provisions which the AICPA has long-advocated.
February 27, 2026 - AICPA Letter on Professional Degree Designation ED RISE NPRM
Following the release of the Department of Education’s Notice of Proposed Rulemaking (NPRM) titled Reimagining and Improving Student Education, the AICPA submitted its response acknowledging the Departments efforts to clarify the definition of “professional,” and urging the incorporation of similar language into the final rule, making the intent clear within the Code of Federal Regulations itself.
February 27, 2026 - AICPA Comments Requesting Penalty Relief for Qualified Farmers
In a letter submitted to the Internal Revenue Service (IRS), the AICPA requested penalty relief for qualified farmers due to changes made to instructions for Form 8995, Qualified Business Income Deduction Simplified Computation. The changes create a shortened filing window and may cause a disadvantage to some qualified farmers outside of their control.
February 25, 2026 - AICPA Comments Requesting IRS Guidance for Limitation on Itemized Deductions and Trump Accounts
The AICPA requested immediate guidance regarding the section 68 limitation on itemized deductions (LID) and section 530A Trump accounts. The comments requested clarification of the new 2/37ths limitation on itemized deductions for individuals, trusts, and estates. Additionally, the comments included gift tax reporting for contributions to Trump accounts, as well as a request for guidance regarding the election to open and the maintenance of Trump accounts.
February 19, 2026 - AICPA Comments on Rev. Proc. 2025-28 Section 6 Concerning Section 174A Domestic Research and Experimentation Expenses
In a letter sent to the Department of the Treasury and the Internal Revenue Service (IRS), the AICPA recommends that Treasury and the IRS issue guidance, through modifications to Rev. Proc. 2025-28 and/or other published guidance regarding the capitalization and amortization of domestic R&E under section 174A(c).
February 4, 2026 - AICPA Comment Letter on Notice 2025-75, Transition Rule for Applying Section 951(a)(2)(B)
The AICPA sent a comment letter to Treasury and IRS providing recommendations to modify and simplify the “determine and document” requirement in Notice 2025-75 by either eliminating or significantly paring back the documentation requirement or alternatively adopting a per se rule or safe harbor.
January 29, 2026 - AICPA Comment Letter on IRS Contingency Plan for Possible Government Shutdown
The AICPA sent a comment letter to Treasury and the IRS requesting the IRS release a contingency plan retaining 100% of IRS employees in the event of a government shutdown on January 31, 2026, which would severely impact the 2026 filing season.
January 15, 2026 - AICPA Letter of Support for Working Families Tax Relief Act
The AICPA sent a letter to Representative Sara Jacobs (D – California) and Senator Amy Klobuchar (D – Minnesota) to express support for introduction of companion bills H.R. 6645/S. 3432, the Working Families Disaster Tax Relief 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) and the Child Tax Credit (CTC).
January 5, 2026 - AICPA Comment Letter Recommends Automating Section 1033 Extension Requests
The AICPA’s first comment letter of 2026 recommends that the IRS develop an automated procedure to process extension requests for taxpayers affected by federally declared disasters to replace involuntarily converted property under section 1033. The recommended process would significantly reduce the IRS’s need to allocate resources to these types of requests and afford taxpayers certainty when attempting to replace property destroyed by disasters.