The APA testified in September at an IRS public hearing in support of proposed rules to lower the filing threshold for electronic filing to an aggregated 100 returns filed in 2022 and 10 returns filed in years after 2022 (86 F.R. 39910, 7-23-21).
For many years, APA has asked for increased electronic capabilities and to lower the threshold for electronic filing. Both the IRS and Social Security Administration have worked hard to create electronic filing opportunities.
Need for Awareness Campaign
“So, let’s talk about the albatross with this rulemaking — the forms subject to this rulemaking are managed by different departments within employer organizations,” APA said. “To comply with the proposed aggregation requirements means extra effort to create processes and procedures internally.” Some additional resources are likely required because internal electronic systems, such as accounts payable and payroll, are not integrated.
The solution is not to back away from electronic filing requirements and maintain the high costs for paper filing by agencies and employers, APA said. What we can do is a better job of creating awareness and continue to improve electronic systems.
The APA encouraged the IRS to work with stakeholders to distribute information about the rulemaking once final.
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Alice P. Jacobsohn, Esq., is Director of Government Relations for the APA.