January 5, 2007
The Honorable
Max Baucus
Chairman
Senate Finance
Committee
219 Senate
Dirksen Office Building
Washington,
D.C. 20515
Fax:
202-228-0554
The Honorable
Charles E. Grassley
Ranking
Member
Senate Finance
Committee
219 Senate
Dirksen Office Building
Washington,
D.C. 20515
Fax:
202-228-0554
RE:
Joint Committee on Taxation Options to Close the Tax Gap
Dear Chairman Baucus and Ranking
Member Grassley:
The American Institute of
Certified Public Accountants supports the Senate Finance Committee’s efforts to
identify constructive ways to close the tax gap, particularly in light of the
current estimate of about $345 billion in lost revenues for the U.S Treasury.
You can be assured we are strongly interested in providing the Finance Committee
with continuing, thoughtful input as your committee’s investigation of this
critical tax administration matter moves forward. Therefore, we are pleased to
respond to the Finance Committee’s October 19, 2006 press release which requests
comments on certain tax gap initiatives that are taken from the August 3, 2006
Joint Committee on Taxation staff report, Additional Options to Improve
Compliance.
Our comments address the
proposals that call for: (1) imposing basis reporting requirements for
publicly-traded securities; (2) expanding the reporting requirements for (a)
real estate taxes, (b) the proceeds of auction sales, (c) mortgage interest, and
(d) individuals with an interest in offshore bank accounts and offshore trusts;
and (3) denying deductions and credits with respect to untimely returns of
nonresident aliens and foreign corporations. We anticipate soon sending the
Senate Finance Committee a separate letter with respect to the JCT option
involving the self-employment tax for partners and S corporation shareholders of
personal service companies.
The AICPA is the national,
professional association of CPAs, with approximately 350,000 members, including
CPAs in business and industry, public practice, government, and education;
student affiliates; and international
associates. Our members advise on federal, state, and international tax matters
and prepare income and other tax returns for millions of taxpayers. They
provide services to individuals, not-for-profit organizations, small and
medium-sized businesses, as well as America’s largest businesses. It is from
this broad perspective that we offer our thoughts today.
We appreciate the opportunity to
comment on the above tax gap proposals contained in the Joint Committee staff
report. We would be pleased to discuss the content of these comments with you
or your staff at any time. If you have any questions, please contact me at
(212) 773-2858, or jeffrey.hoops@ey.com; James E. Brennan,
Chair of the AICPA IRS Practice and Procedures Committee, at (212) 773-3209, or
james.brennan@ey.com; or Benson
Goldstein, AICPA Technical Manager, at (202) 434-9279, or bgoldstein@aicpa.org.
Sincerely,
Jeffrey R.
Hoops
Chair, Tax Executive
Committee
Click here to see the AICPA Comment