AICPA calls on IRS, Treasury to streamline Sec. 951 documentation rules

The American Institute of CPAs (AICPA) has urged the US Department of the Treasury and the Internal Revenue Service (IRS) to trim documentation burdens successful modulation guidance tied to conception 951(a)(2)(B) nether H.R. 1.

In a missive responding to Notice 2025-75, which addresses taxable years of definite overseas corporations opening earlier 1 January 2026, the AICPA outlined concerns implicit however the existent modulation regularisation operates successful practice.

The AICPA noted that the US taxpayers whitethorn look important hurdles successful accessing elaborate taxation accusation required by the notice. The contented whitethorn peculiarly originate erstwhile transactions person already closed and determination is nary narration with the purchaser oregon contractual work to supply post-closing taxation certifications.

According to the letter, obliging taxpayers to get oregon reconstruct specified accusation risks producing inconsistent results that are beyond their control.

The AICPA’s submission focuses connected the notice’s 'determine and document' requirement, which compels taxpayers to amusement that specified dividends accrued taxable income. It recommends that this work beryllium removed oregon importantly scaled back.

As an alternative, it suggests a per se regularisation oregon harmless harbour nether which the 'determine and document' request would not use to dividends received by definite US persons for whom inclusion successful taxable income is mandatory nether the Internal Revenue Code.

For different situations, the AICPA urges Treasury and the IRS to clarify that wide national income taxation principles should beryllium applied. It besides urges them to specify what forms of documentation are capable to show that a dividend has accrued taxable income.

AICPA Tax Policy and Advocacy elder manager Reema Patel said: “This guidance does not explicate what level of analysis, substantiation oregon third-party accusation is required to complying with the 'determine and document' requirement.

“In addition, galore transactions to which the modulation rules use person already closed, making the AICPA’s recommendations adjacent much essential.”

"AICPA calls connected IRS, Treasury to streamline Sec. 951 documentation rules" was primitively created and published by The Accountant, a GlobalData owned brand.

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