Comment Letters

Pennsylvania Senate

• Memo to Senate Finance Committee - Please Support House Bill 17 - Dated Oct. 21, 2019
• Email to Senate State Government Committee - Please Support House Bills 1420 and 1421 - Dated Oct. 24, 2017
• Email to Senate Finance Committee - Please Support House Bill 866 - Dated June 26, 2017
• Email to Full Senate - Please Support House Bill 866 - Dated June 28, 2017
• Email to Full Senate - Support S.B. 1360 - Compliance with Federal Overtime Rules - Dated March 8, 2017 
• Email to Full Senate - Re: Please Support H.B. 245- Act 32 Amendments - Dated Oct. 25, 2016 
• Email to Full Senate - Support H.B. 245 - Act 32 Amendments - Dated Oct. 24, 2016 
• Senate Labor and Industry Committee – Support S.B. 1360 - Compliance with Federal Overtime Rules - Dated Sept. 26, 2016
• Senate Labor and Industry Committee – Re: Support S.B. 1360: Compliance with Federal Overtime Rules - Dated Sept. 19, 2016
• Senate Judiciary Committee Chair - Please Consider H.B. 1398 - Dated summer 2016 
• Senate Finance Committee Letter – Re: Senate Bill 4 (Constitutional Amendment) – Purely Public Charities Property Tax Exemption - Dated Feb. 3, 2015

Pennsylvania Governor

• Letter to Gov. Tom Wolf - Please Support House Bills 1420 and 1421 - Dated Dec. 15, 2017
• Letter to the Editor from PICPA President, Lisa Myers -Re: H.B. 245 - Dated Nov. 14, 2016
  • Letter to the Editor: Wolf veto won’t stop CPA fight on taxes - The Delaware County Daily Times - Nov. 14, 2016 
  • CPA's Will Fight 'Double Taxation', Despite Governor Wolf Veto - Limerick Patch - Nov. 15, 2016
  • CPA's Will Fight 'Double Taxation', Despite Governor Wolf Veto - Roxborough Patch - Nov. 15, 2016
  • Tax bill veto faulted - The Times-Tribune - Nov. 16, 2016 
  • Fight to protect taxpayers continues - The Citizen's Voice - Nov. 17, 2016 
  • CPAs disappointed by Gov. Tom Wolf’s veto of bill that, they say, discouraged double taxation-Times Leader - Nov. 18, 2016
  • Wolf's unexpected veto - Tribune-Review - Nov. 21, 2016
  • CPAs continue the fight against double taxation - GoErie.com - Nov. 22, 2016
• Letter to Gov. Tom Wolf - Please Support H.B. 245 - Act 32 Amendments - Dated Oct. 28, 2016
• Letter to Gov. Tom Wolf - Please Support S.B. 1018 - CPA Law Amendments - Dated Oct. 28, 2016

Pennsylvania House of Representatives

• Email to Full House - Please Support House Bill 706 - Amendment A00529 - Dated April 15, 2019
• Memo Email to House Finance - Please Support HB 706 - Dated March 25, 2019
• Email to House Finance - Please Support A09950 to HB 2413 - Dated Oct. 8, 2018
• Joint letter from PICPA, Association of Independent Colleges & Universities, PA Credit Union Association re: Keystone Scholars Program - Dated June 19, 2018 
• Joint letter from PICPA and PA Chamber re: Tax Appeals - Dated Aug. 2, 2017
• Email to Full House - Please Support House Bills 1420 and 1421 - Dated June 13, 2017
• Email to Full House -Please Support House Bill 866 - Dated June 12 , 2017
• Email to House Finance - Please Support House Bills 1420 and 1421 - Dated June 6, 2017
• Email to House Leadership -Please Support Senate Bill 1 - June 6, 2017
• Letter to Freshman Legislators - Re: Property Tax Reform - Dated Jan. 17, 2017
• Email to Full House - Please Support H.B. 245- Act 32 Amendments - Dated Oct. 26, 2016
• PA House Bill 946, the Pharmacy Audit Integrity Act - Dated Oct. 12, 2015
• Letter to Chairwoman Julie L. Harhart in Support of House Bill 92 - Dated March 30, 2015
• PICPA Opposes Sales Tax on Services – A Letter to House Appropriations Chairman, Rep. Bill Adolph - Dated March 25, 2015

Pennsylvania Department of Revenue

• PICPA Comments Re: Delay Implementation of New 1099-MISC Withholding Requirement - Dated Jan. 26, 2018

• PICPA Comments on Department of Revenue Draft Marketplace Sales Guidance - Dated Jan. 22, 2018

• Re: Department of Revenue Proposed Regulation "Withholding of Tax" (#15-459) - Dated Nov. 27, 2017

• Re: Comments on Draft Realty Transfer Tax Regulations—Oct. 2017  - Dated Nov. 14,  2017

• Philadelphia Bar Association Comments on Draft Realty Transfer Tax Regulations - Dated Nov. 13, 2017

• Dept. of Revenue Comment Letter on Draft Sales & Use Tax Bulletin 2016-02 - Letter to C. Daniel Hassell, Deputy Secretary for Tax Policy - Dated Dec. 22, 2016 

• Dept. of Revenue Information Notice Corporation Taxes 2016-01 - Letter to C. Daniel Hassell, Deputy Secretary for Tax Policy - Dated Feb. 16, 2016

• Dept. of  Revenue Information Notice Corporation Taxes 2014-01 – Letter to C. Daniel Hassell, Deputy Secretary for Tax Policy - Dated March 24, 2015

Pennsylvania Department of Community & Economic Development

• Pennsylvania Local Tax Enabling Act Comment Letter - Dated July 12, 2018
• Pennsylvania Film Production Tax Credit Comment Letter - Dated Jan. 9, 2017

Supreme Court of Pennsylvania 

• Mission Funding Alpha v. Commonwealth of PA
  
  

Pennsylvania Department of Human Services

• Re: Department of Human Services Single Audit Supplement - Dated Aug. 17, 2015

Pennsylvania Insurance Department

• Re: Annual Financial Reporting Requirements 11-254 (IRRC #3129) Insurance Regulations - Dated Feb. 17, 2016

Pennsylvania Department of Labor & Industry

• Joint Letter re: Request to Extend Public Comment Period for Overtime Proposal - Dated June 29, 2018

Pennsylvania Department of Health

• Re: Pennsylvania Regulations for Medical Marijuana – Involvement of CPAs - Dated Aug. 1, 2016

Pennsylvania Department of Treasury 

• Fiduciary Accounts/Unclaimed Property Comment Letter - Dated Dec. 16, 2016 

Pennsylvania Department of State

• PICPA Comments re: Reg 16A-60 Expungement - Dated July 22, 2019

U.S. Senate

• Comment letter to U.S. Sens. Rob Portman and Benjamin Cardin regarding the Protecting Taxpayers Act - Dated Aug. 27, 2018 
• Requesting PA Senators support S. 540 – Mobile Workforce Income Tax Simplification Act in the upcoming government spending legislation - Dated Feb. 28, 2018 
• Letter to PA Delegation Re: Tax Reform - Dated Nov. 3, 2017
• State Societies re: Mobile Workforce Cosponsorship - Letter to Sen. Bob Casey - Dated April 27, 2017
• State Societies re: Mobile Workforce Cosponsorship - Letter to Sen. Pat Toomey- Dated April 27, 2017
• Partnership to Protect Workplace Opportunity – Letter to U.S. Senate in Support of S. 2707, Protecting Workplace Advancement and Opportunity – Dated April 18, 2016
• Letter to Sen. Pat Toomey in Support of the Mobile Workforce State Income Tax Simplification Act –  Dated March 3, 2016
• Letter to Sen. Robert P. Casey Jr. in Support of the Mobile Workforce Income Tax Simplification Act – Dated March 3, 2016
• Partnership to Protect Workplace Opportunity – Letter to the Department of Labor, the Office of Management, and Budget's Office of Internal and Regulatory Affairs in opposition to exemptions for executive, administrative, and professional employees to the Fair Labor Standard Act's overtime pay requirements – Dated Dec. 7, 2015
• Letter to Sen. Robert P. Casey Jr. in Support of the Brown-Thune Mobile Workforce Amendment – Dated Feb. 6, 2015
• Letter to Sen. Pat Toomey in Support of the Brown-Thune Mobile Workforce Amendment – Dated Feb. 6, 2015

U.S. House of Representatives

• Requesting Support of Select members of the Pa. House re: Please Cosponsor Fiscal State of the Nation Resolution - October 10, 2019
• Taxpayer First Act Discussion Draft, U.S. House Subcommittee on Oversight – PICPA Federal Tax Committee Response to the Discussion Draft – Dated March 31, 2018
• Requesting PA Representatives support S. 540 – Mobile Workforce Income Tax Simplification Act in the upcoming government spending legislation – Dated Feb. 28, 2018 
• AICPA Letter to Committee on Small Business Chairman, Steve Chabot, & Ranking Member, Rep. Nydia Velázquez – RE : Hearing on "Startups Stalling? The Tax Code as a Barrier to Entrepreneurship" – Dated Feb. 15, 2017
• AICPA Letter to House Committee on Ways & Means Chairman, Rep. Kevin Brady – RE: The House Republican’s Tax Reform Task Force Blueprint – Dated Dec. 21, 2016 
• H.R. 5813, the Overtime Reform and Enhancement Act (OREA)  –  Letters to PA Congressional Delegation requesting co-sponsorship of the Overtime Reform and Enhancement Act (OREA)  – Dated Sept. 8, 2016
• Partnership to Protect Workplace Opportunity – Letter to the U.S. House Committee in Support of S. 4773, Protecting Workplace Advancement and Opportunity – Dated June 9, 2016
• Partnership to Protect Workplace Opportunity – Letter to U.S. House Committee in Support of S. 4773, Protecting Workplace Advancement and Opportunity – Dated April 18, 2016
• U.S. House - H.R. 2911, the Small Business Healthcare Relief Act of 2015 Support Letter - Dated Sept. 16, 2015

U.S. Department of Labor

• Re: RIN 1210-AB63 - Federal Register Vol. 81, No. 140 Thursday, July 21, 2016/Proposed Rules - Proposed Revisions to Form 5500 - Dated Nov. 14, 2016

Internal Revenue Service 

• RE: Recommendations for 2019-2020 Guidance Priority List (Notice 2019-30) - June 7, 2019
• Re: Comments on Parking Expenses for Qualified Transportation Fringes under Section 274( a)(4) and Section 512 (a)(7) of the Internal Revenue Code - Dated Feb. 22, 2019 
• Re: IRS Immediate and Interpretive TCJA Guidance Request 2018 – 2019 - Dated June 15, 2018
• RE: REG-136118-15 (RIN 1545-BN77) Regarding Centralized Partnership Audit Regime - Dated Aug. 10, 2017
• RE: Notice 2017-17 - Proposed Revenue Procedure Guidance for Requesting Accounting Method Changes Resulting or Related to the Adoption of New Financial Accounting Standards for the Recognition of Revenue - Dated July 24, 2017

American Institute of CPAs (AICPA)

• Re: Proposed Statement on Standards for Attestation Engagements – Clarification and Recodification - Dated Oct.10, 2018
• Re: AICPA PEEC – Proposed Interpretation and Other Guidance – State and Local Government Entities - Dated Oct. 6, 2017
• Re: AICPA/NASBA Uniform Accountancy Act (UAA) - Dated Sept. 27, 2017
• Re: Proposed Statement on Auditing Standards (SAS), AU-C Section 703, "Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA" - Dated July 28, 2017
• Re: 2017 Discussion Paper: Proposed Evolution of Peer Review Administration - Dated June 13, 2017
• Re: SSARS 23 – Omnibus Statement on Standards for Accounting and Review Services – 2016 - Dated March 16, 2017
• Re: Omnibus Proposal – Proposed Revised and New Interpretations Applicable to Members in Business - Dated March 16, 2017
• Re: Proposed Statement on Auditing Standards – The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern - Dated Sept. 1, 2016
• Re: Proposed Mandatory Performance Framework for the Fair Value Quality Initiative and Proposed Application - Dated Aug. 24, 2016
• Re: Proposed Statements on Standards for Accounting and Review Services (SSARSs) - Dated May 4, 2016
• Re: Exposure Draft on Statement on Standards for Continuing Professional Education (CPE) Programs Jointly Issued by the American Institute of Certified Public Accountants (AICPA) and the National Association of State Boards of Accountancy (NASBA) - Dated Aug. 26, 2015
• Re: Evolving the CPA Profession’s Peer Review Program for the Future Concept Paper - Dated June 15, 2015

Governmental Accounting Standards Board (GASB)

• GASB Comment Response: Subscription-Based Information Technology Arrangements – Project No. 38 and Public-Private and Public-Public Partnerships & Availability Payment Arrangements - Project No. 30-1 - Dated Aug. 15, 2019
• GASB Comment Response: Omnibus 20XX - Project No. 37-1 and Internal Revenue Code Section 457 - Deferred Compensation Plans That Meet the Definition of a Pension Plan & Supersession of GASB Statement 32 - Project No. 3-33 - Dated Aug. 15, 2019
• GASB Comment Response: Proposed Implementation Guide on Leases - Project 3-24 - Dated Apr. 29, 2019
• GASB Committee Response: Financial Reporting Model Improvements - Project 3-25 - Dated Feb. 13, 2019
• GASB Committee Response: Recognition of Elements of Financial Statements - Project 3-20 - Dated Feb. 13, 2019
• GASB Committee Response: Implementation Guidance Update - Project No. 24-16d - Dated Jan. 30, 2019
• GASB Committee Response: Conduit Debt Obligations - Project No. 26-6 - Dated Oct. 2, 2018 
• GASB Committee Response: Revenue and Expense Recognition, Project No. 4-6I - Dated March 28, 2018 
• GASB Committee Response: Implementation Guide No. 201Y-X: Project 24-16ED- Dated Feb. 12, 2018
• GASB Committee Response: Accounting for Interest Cost during the Period of Construction: Project 9-5 - Dated Feb. 12, 2018
• GASB Project 3-30 Certain Disclosures Related to Debt - Dated Sept. 5, 2017
• GASB Committee Response on Financial Reporting Model Improvements-Governmental Funds Project 3-25I - Dated March 13, 2017 
• GASB Committee Response to 201X-Y Implementation Guide - Dated Jan. 23, 2017
• GASB Committee Response to OPEB Implementation Guide - Dated Nov. 18, 2016
• GASB Project 37E Proposed Statement on Omnibus 201X Exposure Draft - Dated Nov. 7, 2016
• GASB Project 3-24E Proposed Statement on Leases- Dated May 26, 2016
  
• GASB Project 3-13E Proposed Statement on Fiduciary Activities- Dated Feb. 11, 2016
• GASB Project 34E Proposed Statement Regarding Pension Issues- Dated Feb. 11, 2016
• GASB_Project_No _3-27E Proposed Statement on Certain Asset Retirement Obligations - Dated Feb. 11, 2016
• GASB Project No. 34 Multiple-Employer Defined Benefit Pension Plans - Dated Nov. 10, 2015

• GASB Project No. 3-28-E Blending Requirements for Certain Component Units - Dated Sept. 10, 2015
• GASB Project No. 3-26-E Accounting and Financial Reporting for Irrevocable Split-Interest Agreements- Dated Sept. 10, 2015
• PICPA Local Government Accounting and Auditing Committee – Re: Project 3-13P, Financial Reporting for Fiduciary Responsibilities- Dated March 2, 2015
• PICPA Local Government Accounting and Auditing Committee – Re: Project No. 3-24P Leases - Dated March 2, 2015

American Institute of CPAs (AICPA) Professional Ethics Division

• Re: Exposure Draft – Client and Attest Client – Proposed Revised Definitions of Client and Attest Client as well as Related Definitions, Interpretations, and Other Guidance - Dated May 15, 2017

Government Accountability Office (GAO)

• Re: Proposed Changes to Government Auditing Standards (commonly known as Yellow Book) – 2017 Exposure Draft  - Dated July 6, 2017

National Association of State Boards of Accountancy (NASBA) and AICPA

• Re: Exposure Draft on Statement on Standards for Continuing Professional Education (CPE) Programs Jointly Issued by the American Institute of Certified Public Accountants (AICPA) and the National Association of State Boards of Accountancy - Dated Aug. 26, 2015

Public Company Accounting Oversight Board (PCAOB)

• Re: PCAOB Release No. 2016-003 Docket 034: Proposed Auditing Standards on the Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion and Related Amendments to PCAOB Standards - Dated July 28, 2016
  

Financial Accounting Standards Board (FASB)

• Re: File Reference No. 2017-270: Proposed Accounting Standards Update, Not-for-Profit Entities (Topic 958) Clarifying the Scope and the Accounting Guidance for Contributions Received and Contributions Made - Dated Oct. 31, 2017
• Re: File Reference No. 2017-200: Proposed Accounting Standards Update—Debt (Topic 470): Simplifying the Classification of Debt in a Classified Balance Sheet (Current versus Noncurrent) - Dated May 4, 2017
• Re: File Reference No. 2017-210: Proposed Accounting Standards Update on Inventory (Topic 330) - Disclosure Framework - Dated Feb. 22, 2017
• Re: File Reference No. 2016-210: Proposed Accounting Standards Update (ASU) – Compensation— Retirement Benefits – Defined Benefit Plans – General (Topic 715-20): Changes to the Disclosure Requirements for Defined Benefit Plans - Dated April 25, 2016
• Re: File Reference No. 2015-350: Proposed Accounting Standards Update (ASU) – Fair Value Measurement (Topic 820): Disclosure Framework – Changes to the Disclosure Requirements for Fair Value Measurement - Dated Feb. 29, 2016
• Re: File Reference No. 2015 – 330: Proposed Accounting Standards Update (ASU) — Business Combinations (Topic 805): Clarifying the Definition of a Business - Dated Feb. 10, 2016
• Re: File Reference No. 2015-340: Proposed Accounting Standards Update, Government Assistance (Topic 832) Disclosures by Business Entities about Government Assistance - Dated Feb. 10, 2016
  
• Re: File Reference No. 2015 – 310: Notes to Financial Statements (Topic 235) Assessing Whether Disclosures Are Material - Dated Dec. 8, 2015

Financial Accounting Foundation (FAF)

• Re:Private Company Council Review - Dated May 15, 2015

International Ethics Standards Board for Accountants

• Re: IESBA Exposure Draft – Responding to Noncompliance with Laws and Regulations (NOCLAR) - Dated Sept. 4, 2015
• Re: IESBA Exposure Draft – Proposed changes to Part C of the Code Addressing Presentation of Information and Pressure to Breach the Fundamental Principles - Dated Apr. 15, 2015

International Auditing and Assurance Boards

• Re: Exploring the Growing Use of Technology in the Audit, with a Focus on Data Analytics - Dated Feb. 15, 2017