The American Institute of CPAs (AICPA) submitted comments to the Internal Revenue Service (IRS) containing 183 recommendations regarding the 2025-2026 Priority Guidance Plan. The AICPA’s recommendations come from the organization’s Tax Technical Resource Panels (TRP), which cover the following areas: Corporations and Shareholders; Employee Benefits; Exempt Organizations; Individual and Self-Employed; International; IRS Advocacy & Relations; Partnerships; S Corporations; Tax Methods and Periods; and Trust, Estate and Gift Tax.
Each area’s top priority is listed below:
Corporations and Shareholders Tax TRP
- Provide final guidance related to the key definitions and application of the corporate alternative minimum tax under section 55 including regarding mergers and acquisitions issues and clarification of the definition of an Applicable Corporation under section 59(k) and the definition of Adjusted Financial Statement income under section 56A.
Employee Benefits Tax TRP
- Provide a Revenue Procedure related to Section 305 of the SECURE 2.0 Act of 2022, as part of the Consolidated Appropriations Act, 2023, addressing the expansion of the Employee Plans Compliance Resolution System.
Exempt Organizations Tax TRP
- Provide an update on the potential revisions to Rev. Proc. 80-27 regarding group exemption letters as described in Notice 2020-36. Modify Rev. Proc. 80-27 to retain the group exemption letter structure where parent organizations can continue to obtain group exemption letters for their subordinate organizations while eliminating the option for the central organization to file a group return filing.
Individual and Self-Employed Tax TRP
- Provide guidance on applying the state and local tax deduction cap under section 164, 24 including:
- Provide guidance on an S corporation’s inability to specially allocate items and the single class of stock requirement.
- Provide guidance on Notice 2020-75 and section 461 accrual basis taxpayers.
- Provide guidance on Notice 2020-75 and sections 469 and 163 on nonpassive versus passive income and interest expense tracing.
- Provide guidance on section 111 application to state tax refunds at the individual level and ordering between passthrough entity income tax payments and nondeductible estimated payments and withholding.
International Tax TRP
- Issue further guidance on the application of sections 959 and 961 to passthrough entities, including treatment of non-recognition transactions.
IRS Advocacy & Relations Committee
- Issue regulations regarding accuracy-related penalties under section 6662, section 6662A, and section 6664. Existing regulations contain outdated rules that misrepresent current law.
Partnership Tax TRP
- Remove Treas. Reg. § 1.6011-18 (Basis Shifting TOI Regulations) from the Income Tax Regulations (26 CFR part 1).
S Corporation Tax TRP
- Issue a revenue procedure modifying the eligibility of any currently effective automatic relief for inadvertent termination or inadvertent invalid S corporation election such that a taxpayer may rely upon multiple revenue procedures to obtain relief for multiple matters affecting S corporation status.
Tax Methods and Periods Tax TRP
- Provide guidance under section 179 for the specific types of assets that qualify as “qualified real property” under section 179.
Trust, Estate, and Gift Tax TRP
- Provide for the ability to e-file the following:
- Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return
- Form 706-NA, U.S. Estate (and Generation-Skipping Transfer) Tax Return – Estate of Nonresident Not a Citizen of the U.S.
- Form 709, U.S. Gift (and Generation-Skipping Transfer) Tax Return
- Provide taxpayers with the ability to electronically pay estate, gift and generation-skipping transfer taxes.
“The AICPA’s Guiding Principles of Good Tax Policy provide a framework of tax principles by which we analyze tax proposals and help promote an effective tax system based on good tax policy,” said Eileen Sherr, Director of Tax Policy & Advocacy for the AICPA. “The comments provided in this letter support the principles of simplicity, effective tax administration, convenience of payment and certainty, and we urge Treasury and the IRS to consider our proposals for needed guidance.”
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