The American Institute of CPAs (AICPA) urged US Congress on May 7 to correct and clarify current international tax provisions in the Internal Revenue Code.
The AICPA submitted its recommendations to the Senate Finance Committee and the House Ways & Means Committee, it said in a statement.
It proposed that Congress:
- Provide legislation to explain the limited nature of the section 958(b)(4) repeal.
- Allow taxpayers with outstanding section 965(h) installments to obtain a refund for tax overpayments, regardless of any future installment amounts of section 965 transition tax liability.
- Consolidate the reporting of foreign assets under Title 31 and Title 26 into a single report.
- For purposes of assessing penalties related to international information reporting, permit an automatic 6-month extension time to file international information returns without requiring the filing of Form 7004, Application for Automatic Extension of Time To File Certain Business Income Tax, Information, and Other Returns or Form 4868, Application for Automatic Extension of Time To File US Individual Income Tax Return.
- Explain that the section 78 gross up is unnecessary when foreign taxes are justly attributable to previously taxed earnings and profits distributions.
The AICPA is also considering issuing other tax recommendations to Congress, as well, the group said.
The AICPA is the largest member association representing the CPA profession, with more than 431,000 members in the United States and worldwide, it said.
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