AICPA requests clarity on Sec. 465 reporting relief

By Julia Woislaw

The AICPA has requested that Treasury and the IRS issue a notice clarifying that relief on certain reporting under Sec. 465 will also apply to S corporations.

On Dec. 9, 2019, Treasury and the IRS issued Notice 2019-66 to provide — among other relief — a delay in certain reporting under Sec. 465 at-risk activities until the taxpayer’s 2020 tax year. Recently released forms and instructions for partnerships and S corporations have increased the level of reporting required for the 2019 tax year at a time when such taxpayers are still expected to address volumes of additional guidance from Treasury and the IRS specific to the law known as the Tax Cuts and Jobs Act, P.L. 115-97.

Notice 2019-66 provides temporary reporting relief for certain items that were considered the most burdensome to partnerships. The AICPA believes that the additional time for partnerships to comply with such provisions will result in better overall compliance.

  • In a Jan. 8 comment letter, the AICPA recommended that Treasury and the IRS clarify that the portion of the notice that provides reporting relief regarding Sec. 465 at-risk activities also apply to S corporations and issue additional guidance on Sec. 465 reporting.

In other advocacy news:

Protecting the CPA license. The Alliance for Responsible Professional Licensing (ARPL), of which the AICPA is a founding member, continues to work to promote a responsible, balanced approach to professional licensing. Recently, the ARPL developed videos of CPAs, engineers, and architects, explaining why licensing matters.

Comments on proposed regulations. The AICPA issued recommendations to Treasury and the IRS on proposed regulations regarding eligible terminated S corporations under Sec. 1371(f) of the Internal Revenue Code.

New revenue recognition standard. The new revenue recognition standard is effective for private companies and many not-for-profits in calendar year 2019 and may be a challenge for many organizations. When CPA firms’ attest clients ask for implementation help, CPAs are faced with the task of maintaining their independence. The AICPA has compiled resources for CPAs who have questions.

Julia Woislaw is lead manager–CPA Evolution for the AICPA. To comment on this article or to suggest an idea for another article, contact Ken Tysiac, the JofA’s editorial director, at


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