The American Institute of CPAs sent a list of
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In all, the letter contains 193 recommendations from 10 different AICPA technical resource panels.
The AICPA also asked the Treasury and the IRS to continue pursuing tax simplification, recognizing the balance needed for competing interests and concerns when drafting guidance, while urging the following to be part of the process:
- Use the simplest approach to accomplish a policy goal;
- Provide safe harbor 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 recommendations ensure that the IRS guidance reflects practical, real-world application for taxpayers and practitioners,” said Kristin Esposito, director of AICPA tax policy and advocacy, in a statement Friday. “Given that our recommendations are ranked by priority within each area, we encourage a focus on the highest-priority items.”
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