The AICPA’s 990 Task Force said the changes improve transparency of reporting, aiding in performance assessment and oversight. The panel is concerned, however, that rushing implementation of the changes will impose significant costs on taxpayers and the IRS and may deter taxpayers’ efforts to improve the overall quality of tax reporting.
The panel recommends the IRS add an executive summary to highlight key information and give users at least a year to implement changes after the reporting requirements have been finalized and published.
The AICPA’s recommendations to accommodate successful implementation of the redesigned Form 990 include:Timely communication with Form 990 users throughout the development process.
Development and testing of systems to process new reported information, including strategizing on alternatives to improve enforcement effectiveness.
Communication of reporting requirements to software developers.
Seeking feedback from other regulatory agencies on the changes.
Educating reporting organizations and their advisers on the changes to give them time to implement internal reporting changes.
The AICPA also recommends changes to enhance clarity and consistency in compensation reporting.
The AICPA’s letter to the IRS commenting on the redesigned Form 990 is available at www.irs.gov/pub/irs-tege/redesignedform990comments_aicpa.pdf or http://tax.aicpa.org/.