AICPA Comments on Proposed Regulations Governing the Reduction of Tax Attributes for S Corporations that Exclude Discharge of Indebtedness under Section 108b

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AICPA Comments on Proposed Regulations Governing the Reduction of Tax Attributes for S Corporations that Exclude Discharge of Indebtedness under Section 108(b)




January 12, 2009 The Honorable Douglas H. Shulman Commissioner of Internal Revenue CC:PA:LPD:PR (REG-102822-08) Courier's Desk 1111 Constitution Avenue, N.W. Washington, D.C. 20224 RE: Comments on Proposed Regulations under Section 108(b) (REG-102822-08) Concerning Reduction of Tax Attributes for S Corporations Dear Commissioner Shulman: Enclosed are comments on proposed regulations under section 108 of the Internal Revenue Code, regarding the application of attribute reduction for S corporations, as prepared by members of the S Corporation Technical Resource Panel of the American Institute for Certified Public Accountants (AICPA) and approved by the AICPAs Tax Executive Committee. We believe that the proposed regulations create certain unintended inequities that run contrary to the statutory requirement that items of income, gain, loss, deduction and credit be allocated pro rata to all shareholders. We would also like clarification on the reduction of C corporation attributes; whether S or C attributes are reduced first; and the application to at-risk and passive activity losses. Not least, we believe the proposed regulations will increase the filing of amended returns and therefore ask that the rules reduce dependence on shareholder reporting to the S corporation. If you have any questions about these comments, please contact Horacio Sobol, Chair of the S Corporation Taxation Technical Resource Panel at horacio.sobol@us.pwc.com; or Marc A. Hyman, AICPA Technical Manager at mhyman@aicpa.org. Very Truly Yours, Alan R. Einhorn, Chair Tax Executive Committee Download Comments




Copyright © 2009 by the American Institute of Certified Public Accountants, Inc. New York, New York.