AICPA Tax Policy and Advocacy Successes: 2025 Highlights

Why It Matters

The wins lower compliance burdens and preserve tax planning tools for accountants and their clients, while shaping future legislative and regulatory agendas. This reinforces the AICPA’s role as a pivotal voice in tax policy formation.

Key Takeaways

• Eight legislative wins, seven bills enacted, PTET provision blocked
• 12 Treasury/IRS guidance items adopted AICPA recommendations
• IRS withdrew/modifed six regulations after AICPA input
• Three states passed AICPA-supported tax legislation
• AICPA secured disaster filing extensions and clearer IRS notices

Pulse Analysis

The Association of International Certified Professional Accountants (AICPA) leveraged its Tax Policy and Advocacy division to drive a record number of successes in 2025, underscoring the organization’s strategic clout in Washington. By championing seven bills that became law—including extensions of research‑and‑development expensing, higher 1099‑K thresholds, and expanded family‑leave credits—the AICPA helped shape the One Big Beautiful Bill Act’s core provisions. Equally critical was the defeat of a proposed SALT‑cap provision that would have eliminated state passthrough entity tax regimes, preserving a valuable planning tool for high‑income taxpayers.

Beyond legislation, the AICPA’s influence permeated regulatory guidance, with twelve Treasury and IRS issuances directly reflecting its recommendations. The association’s comment letters prompted the IRS to modify or withdraw six regulations, ranging from partnership basis‑shifting rules to corporate alternative minimum tax guidance. Targeted relief measures—such as expanded digital‑asset reporting windows and disaster‑related filing extensions—addressed immediate taxpayer pain points, while clearer IRS notices reduced administrative friction for estates and trusts. These regulatory wins demonstrate how coordinated advocacy can translate technical expertise into concrete policy adjustments.

State‑level advocacy also yielded tangible outcomes, as three states enacted tax measures aligned with AICPA‑backed model legislation, and another state averted a detrimental sales‑tax proposal. Looking ahead to 2026, the AICPA plans to advance pending bills like the Mobile Workforce State Income Tax Simplification Act and the TAS Act, while continuing to monitor IRS modernization efforts. For tax professionals, these developments signal a more predictable regulatory environment and underscore the importance of staying engaged with AICPA resources to navigate evolving compliance landscapes.

AICPA tax policy and advocacy successes: 2025 highlights

Eileen Reichenberg Sherr, CPA, CGMA, MT · Director, Tax Policy & Advocacy, Association of International Certified Professional Accountants

As we look back on 2025, the AICPA Tax Division’s Tax Executive Committee, along with its 14 committees, technical resource panels, and various task forces, achieved over 40 tax advocacy successes and produced more than 68 comments.

Highlights of our tax advocacy successes

• Eight tax legislative successes, including the enactment of seven AICPA‑supported bills and the elimination of a proposed provision that would have prohibited the use of state passthrough entity tax (PTET) regimes by taxpayers affected by the federal SALT deduction cap.

• 12 Treasury and IRS guidance items that incorporated AICPA recommendations.

• Six IRS modifications and withdrawals of regulations on which the AICPA raised concerns.

• Six IRS relief provisions that the AICPA requested.

• Inclusion in the IRS National Taxpayer Advocate’s annual report of the AICPA’s recommendation to reallocate or provide additional funding for taxpayer service and modernization, and reference to an AICPA report on civil penalties.

• Correction of accounts that received erroneous IRS notices of estimated payments on Form 1041 (U.S. Income Tax Return for Estates and Trusts) when the 100 % prior‑year safe‑harbor applied, as the AICPA advocated.

• Three states enacted AICPA‑ and state‑CPA‑society‑supported legislation or regulations; one state did not enact legislation the AICPA opposed.

While 2026 is expected to be a busy year for federal tax policy, below is a closer look at some of the AICPA’s 2025 tax advocacy successes.

---

AICPA advocacy affects federal tax legislation

The AICPA, together with state CPA societies, successfully advocated for the elimination of a proposed federal provision that would have prohibited PTET regimes in states with taxpayers affected by the SALT cap. Additional tax reconciliation advocacy successes are noted below.

The AICPA endorsed 19 bills in the 119th and 118th Congresses, and seven AICPA‑supported bills were enacted.

Four of the enacted AICPA‑supported bills were part of the July 4, 2025 tax reconciliation legislation (H.R. 1, P.L. 119‑21, commonly known as the One Big Beautiful Bill Act – OBBBA):

1. Extending Sec. 174 research‑and‑experimentation (R&E) expensing (S. 1639/H.R. 1990, American Innovation and Jobs Act).

2. Increasing the reporting threshold for Form 1099‑K from $600 to $20,000 (Red Tape Reduction Act) and to $10,000 in S. 1761.

3. Extending the paid family and medical leave tax credit (S. 400/H.R. 996, Paid Family and Medical Leave Tax Credit Extension and Enhancement Act).

4. Allowing Sec. 529 plan expenses for post‑secondary credentials, including the CPA Exam (S. 756/H.R. 1151, Freedom to Invest in Tomorrow’s Workforce Act).

The other three enacted AICPA‑supported bills were in separate legislation:

• Providing the IRS authority to extend federal tax filing deadlines after a state‑declared disaster and expanding the mandatory extension from 60 to 120 days (H.R. 517/S. 132, Filing Relief for Natural Disasters Act).

• Extending the time disaster victims have to file a tax refund or credit claim to include the disaster postponement rather than the original deadline (H.R. 1491, Disaster Related Extensions of Deadlines Act).

• Requiring clearer information on math and clerical error IRS notices (H.R. 998, Internal Revenue Service Math and Taxpayer Help Act).

In addition, seven other AICPA‑supported provisions were enacted in the H.R. 1 reconciliation legislation, including:

• Raising filing thresholds for Forms 1099‑NEC and 1099‑MISC to $2,000 (inflation‑adjusted).

• Restoring and making permanent Sec. 163(j)(8)(A)(v) for earnings before interest, taxes, depreciation, and amortization.

• Making permanent 100 % bonus depreciation.

• Making permanent the Sec. 199A qualified business income deduction and expanding its limitation phase‑in range.

• Permanently extending the Sec. 954(c)(6) look‑through rule for controlled foreign corporations.

• Restoring the limitation on downward attribution of stock ownership under Sec. 958(b).

• Permanently extending the individual alternative minimum tax exemption and phase‑outs at 2018 levels.

Ongoing legislative priorities

The AICPA continues to support several bills introduced in 2025, including:

• S. 1443 – Mobile Workforce State Income Tax Simplification Act.

• Bipartisan Senate Finance Committee Taxpayer Assistance and Service (TAS) Act – containing 13 AICPA‑supported provisions.

• H.R. 1152 – Electronic Filing and Payment Fairness Act, which would apply the “mailbox rule” to electronic submissions.

The AICPA hopes these bills will advance in 2026, and that additional provisions of the Tax Cuts and Jobs Act (TCJA) will be considered. To aid Congress, the AICPA provided 69 non‑controversial tax legislative proposals for simplification and technical changes to the Internal Revenue Code.

---

AICPA advocacy affected tax regulatory guidance

The AICPA submitted over 68 comment letters and engaged extensively with Treasury and IRS officials. Notable outcomes include:

IRS reports referencing AICPA recommendations

• The 2024 IRS National Taxpayer Advocate Annual Report (issued Jan. 8 2025) cited the AICPA’s recommendation for additional funding for taxpayer service and modernization and referenced the AICPA’s 2013 report on civil tax penalties.

Correction of erroneous IRS notices

• In May 2025, the AICPA identified and helped correct erroneous CP 161 and CP 504B notices for Form 1041 taxpayers who had paid 100 % of prior‑year estimated taxes. The IRS issued Servicewide Electronic Research Program Alert 25A0208 (Sept. 19 2025, revised Nov. 14 2025) and confirmed the corrections on Nov. 17 2025.

IRS modifications and withdrawals of regulations

• Partnership basis‑shifting transaction reporting: The final regulations (T.D. 10028) incorporated three AICPA recommendations, raising thresholds and limiting the look‑back period. Subsequent IRS actions withdrew the final regulations and provided relief from penalties.

• Dual‑consolidated‑loss (DCL) and disregarded‑payment rules: Treasury and the IRS delayed effective dates and withdrew certain regulations after AICPA input.

• Sec. 382(h) regulations: The IRS withdrew proposed regulations and reinstated the AICPA‑suggested approach from Notice 2003‑65.

• Corporate Alternative Minimum Tax (CAMT): Notice 2025‑46 partially withdrew proposed regulations and incorporated several AICPA recommendations.

IRS relief (penalty, filing, and reporting) as requested

• Sec. 174A R&E expensing for small businesses – Rev. Proc. 2025‑8 allowed a deduction election for 2024 returns.

• Sec. 6045 digital assets regulations – Notice 2025‑33 extended relief, postponed final regulations to Jan. 1 2026, and provided transition penalty relief.

• Qualified tips and overtime – Notices 2025‑62 and 2025‑69 gave guidance and relief for employers and individual taxpayers claiming these deductions.

• Digital‑asset basis tracking – Notice 2025‑7 granted transition relief for specific‑identification methods.

IRS clarifications, updated forms, and guidance adopting AICPA recommendations

• Form 6765 (Credit for Increasing Research Activities) – Updated instructions incorporated four AICPA recommendations, simplifying reporting requirements.

• Disaster‑relief bulk filing – The IRS added a fax number (855‑863‑1257) for bulk filing requests, per AICPA request.

• CAMT regulations – Notices 2025‑49, 2025‑27, and 2025‑28 adopted multiple AICPA suggestions, including safe‑harbor expansions and simplified partnership allocations.

• Sec. 2801 estate‑tax expatriation regulations – Adopted three AICPA recommendations on reporting covered bequests and loan treatment.

• Excise tax on corporate stock repurchase – Final regulations incorporated AICPA recommendations to omit a funding rule, eliminate shareholder certification requirements, and provide transition relief.

• Roth mandated catch‑up contributions (SECURE 2.0) – Final regulations adopted AICPA recommendations on Form W‑2 safe harbors and guidance for paymasters.

• Sec. 162(m) (Executive Compensation) – The IRS issued final regulations (Rev. Proc. 2025‑1) raising dollar thresholds, as the AICPA requested.

• Employee Retention Credit (ERC) FAQs – Updated FAQs provided simplified treatment for employers who claimed the ERC but did not reduce wage expense on their tax return.

---

AICPA resources support state CPA societies’ state tax advocacy

The AICPA State and Local Tax Technical Resource Panel and State Advocacy teams provide resources for state CPA societies. In 2025, four state societies achieved notable advocacy victories:

• Alabama – The mobile‑workforce bill (H.B. 379) was amended to a 30‑day threshold, aligning with AICPA‑supported model legislation, and enacted.

• Texas – Updated data‑processing rule amendments (34 Tex. Admin. Code, § 3.330(a)(1)) retained the prior‑rule exception for tax‑return and financial‑statement preparation.

• Georgia – Enacted S.B. 141, increasing the appeals and protest period for tax assessments from 30 to 45 days, moving closer to the AICPA‑suggested 90‑day period.

• Maryland – Successfully opposed legislation that would have imposed a sales tax on professional services, preventing its advancement.

---

Looking ahead to 2026, the AICPA Tax Policy and Advocacy group will continue to champion tax regulatory and legislative matters, including implementation of OBBBA provisions, CAMT, the TAS Act, and ongoing IRS service and modernization initiatives. The AICPA remains committed to keeping members informed of developments and advocacy efforts.

— Eileen Reichenberg Sherr, CPA, CGMA, MT, Director, Tax Policy & Advocacy, Association of International Certified Professional Accountants

To comment on this article or suggest ideas for future articles, contact Paul Bonner at [email protected].