This year’s report of the IRS Advisory Council includes recommendations on 37 issues covering a broad range of topics, among the most important of which are IRS funding and oversight of preparers.

The top general report issues also include IRS Strategic Operating Plan assessment and analysis, hiring, online accounts promotion and technical support, capabilities and authorizations for business online accounts, ID theft and the PTIN database and broader continuing education for Enrolled Agents, among other topics.

“IRSAC members have spent numerous hours analyzing issues in tax administration and the transformation work underway across the IRS,” said IRS Commissioner Danny Werfel. “The IRS is grateful for their hard work.” 

Among the issues and recommendations:

• IRS funding: Noting that many Americans do not understand the tax gap or its impact, and that Congress rescinded some of the IRS funding granted under the Inflation Reduction Act and continues denying inflation adjustments to the IRS base budget, IRSAC recommended greatly improved communication to the public regarding the impact of the tax gap.
• Preparer oversight: The report noted that tax prep businesses “continue to train tax preparers they employ according to their own needs and standards” and that “sole proprietors have complete discretion as to their preparation and training.” Among other recommendations, IRSAC proposed a voluntary Filing Season Agent credential modeled on the Enrolled Agent credential. “Research and publish results regarding accuracy rates among [Annual Filing Season Program] record holders, uncredentialed preparers, and preparers otherwise exempt from AFSP test requirements,” the report suggested.
• EA CE: The 72 hours of continuing education required to renew enrollment for EAs should allow up to four hours of practice management, which could include business organization, communications, marketing and IT, among other topics.

The IRSAC serves as a federal advisory committee to the IRS commissioner and executive leadership. It provides a public forum for discussion of relevant issues in tax administration. IRSAC subgroups cover information reporting, large business and international, small business/self-employed, tax exempt/government entities and taxpayer services. 

Saving Social Security; sued over an address; more 5471 opinions; and other highlights from our favorite tax bloggers.

You will survive

• U of I Tax School (https://taxschool.illinois.edu/blog/): From fielding endless tax questions to relatives’ barrage of requests for help with returns, the accountants’ survival guide to Thanksgiving.
• Tax Vox (https://www.taxpolicycenter.org/taxvox): Could a pre-tariff buying frenzy kick off a new round of inflation?
• TaxProf Blog (http://taxprof.typepad.com/taxprof_blog/): Congress last reformed the nation’s current tax penalty regime some three decades ago, before the rise of big data and the advent of predictive analytics. Is it time for Congress to weave the latter into the Internal Revenue Code?
• Tax Foundation (https://taxfoundation.org/blog) As Social Security faces looming insolvency, one issue that garners a lot of attention in the debate over solutions is raising the payroll tax cap. Policymakers should also recognize that broader changes in how workers are compensated have contributed to the decline in wages subject to payroll taxes. Expanding the payroll tax base to include all forms of worker compensation should be on the table.
• Institute on Taxation and Economic Policy (https://itep.org/category/blog/): A recent analysis shows that some widespread tariffs are beneficial — and that those now proposed wouldn’t be among them.
• Don’t Mess with Taxes (http://dontmesswithtaxes.typepad.com/): What do holiday shopping and taxes share? The growing potential for ID theft.

Just guess

Tricky stuff

• The Tax Times (https://www.thetaxtimes.com): The Tax Court just opined on another case that thwarts IRS authority to assess 5471 reporting penalties.
• Global Taxes (https://www.globaltaxes.com/blog.php): Seems that in Mukhi v. Commissioner, the Tax Court rejected arguments that a due process hearing was conducted by a partial appeals officer and that non-filing penalties violated the Eighth Amendment’s Excessive Fines Clause. The big win was in the third question.
• Withum (https://www.withum.com/resources/): Latest state updates include Washington’s Supreme Court denying an investment income deduction and new services subject to B&O retailing classification in the state.
• TaxConnex (https://www.taxconnex.com/blog-): Execs go into M&A often blindly jazzed about the deal and thinking they know the landmines, such as employees’ reactions or overpaying the target company. What about the risk of past sales tax exposure?
• Palm Beach Accounting and Financial Services (https://www.pbafs.com/blog): Savings bonds, 529 contributions and the good old-fashioned, rattling piggy bank: Gifts that can teach kids about finances.
• Boyum & Barenscheer (https://www.myboyum.com/blog/): What to remind them about the differences between accounting and tax profitability.
• Avalara (https://www.avalara.com/blog/en/north-america.html: A state-by-state look at clothing taxes.
• Vertex (https://www.vertexinc.com/resources/resource-library/filter/field_asset_type/blog?page=0): What to remind them of the complexities of corporate taxes.
• Armanino (https://www.armanino.com/articles/): The latest on issuing 1099s for next season.
• Sovos (https://sovos.com/blog/): Third-party settlement organizations are also keeping a close watch on IRS guidance regarding their obligations under 1099-K requirements. Recent changes to reporting thresholds, coupled with delayed enforcement and conflicting guidance, have left many TPSOs on marshy ground about their responsibilities.
• MBK (https://www.mbkcpa.com/insights): How business-vehicle deductions can be especially “tricky.”
• Virginia – U.S. Tax Talk (https://us-tax.org/about-this-us-tax-blog/): Overseas Americans are entitled to certain tax breaks, one significant break being the exclusion of amounts provided by an employer for foreign housing.
• Gordon Law (https://gordonlawltd.com/blog/): When big hearts co-exist with small tax brains: What to remind them about taxes and charities this giving season.
• Summing It Up (http://blog.freedmaxick.com/summing-it-up): One of the main provisions of Secure 2.0 kicks in on Jan. 1: automatic enrollment for new employee benefit plans.
• AICPA & CIMA Insights (https://www.aicpa-cima.com/blog): Whether accounting for digital assets or auditing entities in this space, to understand the asset class you need to understand the fundamentals of the underlying technology: blockchain.

The Public Company Accounting Oversight Board introduced two pieces of guidance to help auditing firms apply its new quality control standard.

The Securities and Exchange Commission approved the PCAOB’s QC standard in September. QC 1000, A Firm’s System of Quality Control, will require all registered public accounting firms to identify specific risks to their practice and design a quality control system that can safeguard against those risks. The standard will require an annual evaluation of firms’ QC systems and reporting to the PCAOB. It takes effect on Dec. 15, 2025.

To help firms adjust to the upcoming requirements, the PCAOB posted two guidance documents Tuesday. QC 1000 Staff Guidance explains how all firms registered with the PCAOB, including those that don’t audit issuers or SEC-registered brokers and dealers, are affected by QC 1000, but not all requirements of QC 1000 will apply to every firm. The publication offers an overview of the various requirements of QC 1000 and along with staff guidance for firms about how to comply with the standard.

QC 1000 emphasizes accountability, firm culture and the “tone at the top,” and firm governance through requirements for specified roles within and responsibilities for the QC system, including at the highest levels of the firm; quality objectives that link compensation to quality; and, for the largest firms, the requirement of an independent perspective on firm governance, the publication points out.

The other publication is AS 2901 Staff Guidance. In connection with the adoption of the new QC 1000 standard, the PCAOB has expanded the auditor’s responsibility to respond to deficiencies on completed engagements under an amended and retitled AS 2901, Responding to Engagement Deficiencies After Issuance of the Auditor’s Report. In addition to an overview of these changes, this publication includes insights from the PCAOB staff on the scope and applicability of the new requirements, as well as information on responding to engagement deficiencies and documentation. AS 2901 requires firms to take action to respond to all engagement deficiencies identified on completed engagements unless it’s probable that the auditor’s report is not being relied on, the PCAOB noted.