AICPA Advocacy

The request came in an AICPA letter to Treasury and the IRS seeking guidance on how employers should implement changes to the paid family leave credit.

The recommendations include allowing taxpayers to rely on substitute reasonable cause when appropriate, permitting them to reserve the automatic first-time abatement for future use.

The AICPA supports the Taxpayer Assistance and Service Act but seeks further improvements.

In a letter to the IRS and Treasury, the AICPA said enrolling children by default “would promote equitable access, reduce procedural barriers, and strengthen the intended reach of the program.”

Requested guidance can be provided through modifications to Rev. Proc. 2025-28 and/or other published guidance.

The AICPA told Treasury that Notice 2025 75’s “determine and document” requirement is “ambiguous and potentially onerous” and urges replacing it with a simple safe harbor or eliminating it.