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Tax Home > Resources > S Corporations > AICPA Proposes Revenue Ruling on S Corp Shareholder Health Insurance Deductions
AICPA Proposes Revenue Ruling on  S Corp Shareholder Health Insurance Deductions

December 27, 2006

 

Mr. Harry Beker,

Branch Chief - Health & Welfare (CC:TEGE:EB:HW)

Internal Revenue Service

1111 Constitution Avenue, NW, Room 4014

Washington, DC 20224

 

Dear Mr. Beker,

 

Based on recent conversations we’ve had regarding IRS Headliner Volume 163 dated May 15, 2006 that addresses the deductibility of health insurance premiums covering S corporation shareholders, the American Institute of Certified Public Accountants (AICPA) has enclosed a proposed revenue ruling for your consideration. We hope that the IRS will issue clarifying guidance similar to this proposal.

 

The enclosed proposed revenue ruling was drafted by Sydney Traum, a member of our S Corporation Taxation Technical Resource Panel (S Corp TRP), reviewed by the S Corp TRP, and approved by the AICPAs Tax Executive Committee. A draft version of the ruling was also sent to the California Society of CPAs, the Florida Institute of CPAs, and the American Association of Attorney-CPAs at their requests. Each of these organizations approved the ruling noting similar concerns among their constituencies.

 

Please review the proposed revenue ruling and get back to either me at jeffrey.hoops@ey.com; Laura Howell-Smith, Chair of the S Corp TRP at lhowellsmith@deloitte.com; or Marc A. Hyman, AICPA Technical Manager at mhyman@aicpa.org, with any comments you and your staff have. We are happy to continue participating with you in the development of guidance as long as we can be of assistance.

 

Thank you very much for taking the time to speak with us about our concerns and for requesting that we submit a proposed ruling.

 

Sincerely,

 

Jeffrey R. Hoops, Chair

AICPA Tax Executive Committee

 

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