The other day, I noted that the IRS has been getting requests for extensions on the comment period for its new rules on disclosing uncertain tax positions on tax returns, and the American Institute of CPAs is now asking for an extension as well.
During an Ernst & Young webcast earlier this week, Heather Maloy, commissioner of the IRSs Large and Mid-Size Business Division, said the IRS had received several requests to extend the comment period beyond the March 29 deadline (see IRS Gets Ready to Deal with Uncertain Tax Positions). Count the AICPA's among them.
In a letter addressed to Maloy, IRS Commissioner Doug Shulman, and IRS chief counsel William Wilkins, the AICPAs Tax Executive Committee chair Alan Einhorn asked the IRS to extend the comment deadline by 60 days. The AICPA said its members want to provide detailed and helpful comments about Announcement 2010-9, but that the March 29 comment deadline does not provide adequate time to analyze the potential impact of the proposal that, if implemented, would result in a significant change in how taxpayers and their advisors conduct business.
The proposal in the announcement is a significant change in how taxpayers and their advisors conduct business, wrote Einhorn. As such, it offers a unique opportunity to accomplish new and mutual goals, but to do so requires an appropriate amount of time.
The 360,000 members of the AICPA represent the Internal Revenue Services largest constituency of advisors affected by this announcement, he added. Many of the AICPAs members are deeply interested in the proposal and wish to respond with detailed and helpful comments. However, the 60-day comment period provided in the announcement falls at a time when they are working extended hours and long weeks preparing financial statements, tax returns and tax return extensions. This short comment period is not sufficient for our members to study the announcement, analyze its potential impact, talk to their clients and their colleagues, and communicate back to the AICPA so that we (or our members themselves) may provide thoughtful, constructive comments to the Service.
The Service has made great strides in building a stronger relationship with corporate America and tax return preparers. In the spirit of working with you on this change in a productive and well-reasoned manner, we urge you to extend the comment period to allow our members to complete their busy season before the comments are due.
Lets hope they get the extension. After all, the IRS will be getting plenty of other requests for extensions this tax season, from tax practitioners and taxpayers alike.