Washington, D.C. (February 26, 2026) – The American Institute of CPAs (AICPA) has requested guidance from the Department of the Treasury and the Internal Revenue Service (IRS) on how individuals, estates and trusts should report income taxes under the newly enacted H.R. 1 (One Big Beautiful Bill Act). The letter focuses on Section 70111, which modifies the Section 68 limitation on itemized deductions (LID) and also provides comments on Notice 2025‑68, outlining the IRS’s planned regulations for Section 530A Trump accounts, including guidance related to gift tax reporting.
The AICPA is requesting guidance on the following:
Section 68 LID
Section 68 limitation calculation for individual, estate and trust taxpayers whose taxable income exceeds the 37 percent tax rate beginning threshold.
Estates’ and trusts’ LID regarding charitable deductions, income in respect of a decedent deductions, section 642(b) deductions, income distribution deductions, and certain administration expenses deductions, as well as the definition of adjusted gross income under section 67(e).
Notice 2025-28, Section 530A Trump accounts
Gift and generation-skipping transfer tax treatment of Trump account contributions.
Ordering rules for returning excess contributions made to an eligible individual’s Trump account and allocation of gain or loss related to such excess contributions.
Penalty of perjury for authorized individuals electing to open Trump accounts for an eligible individual and clarification of priority listing mechanics.
Automatic enrollment of eligible individuals in Trump accounts and federal pilot program.
Form 8879-TA use with electronically filed tax returns.
New responsible party selection after the Trump account is established.
Clarification of whether an index is composed primarily of U.S. equity investments, and the circumstances under which assets may be held in non‑eligible funds for a de minimis time during the growth period.
“The lack of detailed guidance in these areas creates uncertainty as well as operational and compliance challenges,” said Eileen Sherr, Director of Tax Policy & Advocacy for the AICPA. “Our recommendations will help to create a consistent and reliable framework for income tax deductions and continued account management, reduce administrative burdens and protect beneficiaries.”
About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world’s largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
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Contact: Veronica L. Vera
202-434-9215
Veronica.Vera@aicpa-cima.com