The American Institute of CPAs submitted more than 140 recommendations to the Internal Revenue Service regarding its 2019-20 Guidance Priority List, identifying and prioritizing guidance projects the AICPA believes the U.S. Department of the Treasury and the IRS should address.

The AICPA believes these projects should be addressed through various means, including regulations, revenue rulings, revenue procedures, notices and other published administrative guidance. In the letter, the AICPA gives high priority recommendations for projects related to the implementation of the Tax Cuts and Jobs Act, with recommendations addressing tax issues affecting individuals, businesses and exempt organizations.

These tax issues include projects related to domestic and international businesses and business partnerships; crowdfunding and the shared economy; virtual currency; nonprofit donations; and distribution of 529 plans.

The AICPA urged the IRS to consider the following guidelines:

• 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.

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