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AICPA wants changes in GST tax regulations

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The American Institute of CPAs asked officials in the Treasury Department and the Internal Revenue Service for changes in the final regulations governing generation-skipping transfer tax exemptions.

Last April, the Treasury and the IRS issued final regulations providing guidance describing the circumstances and procedures under which an extension of time will be granted to make certain allocations and elections related to the GST tax. The relief provisions are supposed to offer a kind of safety net for taxpayers so their estate planning and tax strategies can be effectively implemented even if some errors are made initially.

The AICPA sent a comment letter last week in response to the recent GST final regulations in which Treasury and the IRS said they’re prepared to issue further revenue procedures or other guidance when they identify situations for which simplified or automatic relief under Section 2642(g)(1) of the Tax Code would be appropriate and administrable. 

The AICPA suggested the Treasury and IRS should extend the relief provided by Rev. Proc. 2004-46 to tax years 2001 and later. The Treasury and the IRS should also provide a similar revenue procedure to Rev. Proc. 2004-46 for situations in which the donor’s GST exemption has been automatically allocated to a prior transfer, but the donor either did not intend for GST exemption to be allocated or the donor was not aware that GST exemption was allocated to the transfer, the AICPA suggested.

The administrative burden on both taxpayers and the IRS to process private letter rulings for small amounts is disproportionate to the amounts involved, the AICPA pointed out. Extending the relief provided by Rev. Proc. 2004-46 to tax years 2001 and later would streamline the process for taxpayers seeking to allocate their GST exemption to post-2000 transfers, thus reducing the administrative burdens and costs associated with PLRs for both taxpayers and the government.

In addition, extending relief to tax years 2001 and later would help taxpayers who didn’t file gift tax returns for certain gifts to trusts, the AICPA recommended. That would enable taxpayers to make more informed decisions and fix their past mistakes so their GST exemptions can better match their tax planning goals.

“While the final regulations offer a safety net for missed GST elections, the high cost and complexity make the Private Letter Ruling approach impractical for many taxpayers,” said Eileen Sherr, the AICPA’s director of tax policy and advocacy, in a statement Wednesday. “The AICPA’s suggestions will help taxpayers effectively utilize their GST exemptions and reduce unnecessary administrative burdens on taxpayers and the IRS.”

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Accounting

Total college enrollment rose 3.2%

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Total postsecondary spring enrollment grew 3.2% year-over-year, according to a report.

The National Student Clearinghouse Research Center published the latest edition of its Current Term Enrollment Estimates series, which provides final enrollment estimates for the fall and spring terms.

The report found that undergraduate enrollment grew 3.5% and reached 15.3 million students, but remains below pre-pandemic levels (378,000 less students). Graduate enrollment also increased to 7.2%, higher than in 2020 (209,000 more students).

Graduation photo

(Read more: Undergraduate accounting enrollment rose 12%)

Community colleges saw the largest growth in enrollment (5.4%), and enrollment increased for all undergraduate credential types. Bachelor’s and associate programs grew 2.1% and 6.3%, respectively, but remain below pre-pandemic levels. 

Most ethnoracial groups saw increases in enrollment this spring, with Black and multiracial undergraduate students seeing the largest growth (10.3% and 8.5%, respectively). The number of undergraduate students in their twenties also increased. Enrollment of students between the ages of 21 and 24 grew 3.2%, and enrollment for students between 25 and 29 grew 5.9%.

For the third consecutive year, high vocational public two-years had substantial growth in enrollment, increasing 11.7% from 2023 to 2024. Enrollment at these trade-focused institutions have increased nearly 20% since pre-pandemic levels.

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Interim guidance from the IRS simplifies corporate AMT

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Jordan Vonderhaar/Photographer: Jordan Vonderhaar/

The Internal Revenue Service has released Notice 2025-27, which provides interim guidance on an optional simplified method for determining an applicable corporation for the corporate alternative minimum tax.

The Inflation Reduction Act of 2022 amended Sec. 55 to impose the CAMT based on the “adjusted financial statement income” of an “applicable corporation” for taxable years beginning in 2023. 

Among other details, proposed regs provide that “applicable corporation” means any corporation (other than an S corp, a regulated investment company or a REIT) that meets either of two average annual AFSI tests depending on financial statement net operating losses for three taxable years and whether the corporation is a member of a foreign-parented multinational group.

Prior to the publication of any final regulations relating to the CAMT, the Treasury and the IRS will issue a notice of proposed rulemaking. Notice 2025-27 will be in IRB: 2025-26, dated June 23.

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In the blogs: Whiplash | Accounting Today

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Conquering tariffs; bracing for notices; FBAR penalty timing; and other highlights from our favorite tax bloggers.

Whiplash

Number-crunching

  • Canopy (https://www.getcanopy.com/blog): “7-Figure Firm, 4-Hour Workweek: 5 Questions to Ask Yourself.”
  • The National Association of Tax Professionals (https://blog.natptax.com/): This week’s “You Make the Call” looks at Sarah, a U.S. citizen who moved to London for work in 2024. On May 15, 2025, it hit her that she forgot to file her 2024 U.S. return. Was she required to file her 2024 taxes by April 15?
  • Taxable Talk (http://www.taxabletalk.com/): Anteing up with Uncle Sam: The World Series of Poker is back, and one major change this year involves players from Russia and Hungary. After suspension of tax treaties with those nations, players will have 30% of winnings withheld. 
  • Parametric (https://www.parametricportfolio.com/blog): Direct indexing seems to come with a common misunderstanding: On the performance statement, conflating the value of harvested losses with returns. 

Problems brewing

  • Taxing Subjects (https://www.drakesoftware.com/blog): No chill is chillier than the client’s at the mailbox when an IRS notice appears out of the blue. How you can educate — and warn — them about the various notices everybody’s that favorite agency might send.
  • Dean Dorton (https://deandorton.com/insights/): Perhaps because they can be founded on trust, your nonprofit clients are especially vulnerable to fraud.
  • Global Taxes (https://www.globaltaxes.com/blog.php): When it’s your time, it’s your time: The clock starts on FBAR penalties when the tax forms are due and not when penalties are assessed — and even the death of the taxpayer doesn’t extend the deadline.
  • TaxConnex (https://www.taxconnex.com/blog-): Your e-commerce clients can muck up sales tax obligations in many ways. How some of the seeds of trouble might hide in their own billing system.
  • Sovos (https://sovos.com/blog/): What’s up with the five states that don’t have a sales tax?
  • Taxjar (https://www.taxjar.com/resources/blog): Humans are still needed to handle sales tax complexity, with real-world examples.
  • Wiss (https://wiss.com/insights/read/): A business — and business-advising — success story from a California chicken eatery.

Almost half done

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