Society Comment Letters

5/17/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2012-001, a proposed standard that would supersede the PCAOB’s interim standard AU sec. 334, Related Parties. The proposed standard and amendments address evaluation of a company's identification of related party transactions, identifying and evaluating a company's accounting and disclosure of significant unusual transactions and obtaining an understanding of a company's financial relationships and transactions with executive officers sufficient to identify risks of material misstatement.

5/3/12 - The NYSSCPA International Taxation Committee offered comments to the Internal Revenue Service as it identified the reporting of foreign retirement plans, in particular, Canadian registered retirement savings plans and Canadian registered retirement funds (together referred to as “RRSPs”), held by U.S. persons, as a significant issue that deserves additional attention from Treasury and the IRS in order to lend clarity to their tax treatment.

4/19/12 - Response to a request for comments regarding when (and under what circumstances) transfers by a trustee of all or a portion of the principal of an irrevocable trust (Distributing Trust) to another irrevocable trust (Receiving Trust), that result in a change in the beneficial interests in the trust, are not subject to income, gift, estate, or generation-skipping transfer taxes.

3/19/12 - Comments regarding IRB 2012-8, February 21, 2012, REG-130302-10, Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations Reporting of Specified Foreign Financial Assets (T.D. 9567). Temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest.

3/7/12 - Comments on a proposed accounting standards update (a joint project of FASB and IASB) to clarify the principles for recognizing revenue and to develop a common revenue standard for U.S. GAAP and IFRSs.

2/28/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-008 proposing transitional amendments to AU sec. 380, Communication With Audit Committees, and reproposing an auditing standard, Communications with Audit Committees, that would supersede the Board's interim standards AU sec. 380 and AU sec. 310, Appointment of the Independent Auditor, and related amendments to PCAOB standards.

2/10/12 - Comments on a proposed accounting standards update to address the diversity in practice related to entities that invest in real estate. The amendments in this proposed Update would provide accounting guidance for an entity that meets the criteria to be an investment property entity. The proposed amendments also would introduce additional presentation and disclosure requirements for an investment property entity.

2/10/12 - Comments on a proposed accounting standards update of Topic 810, Consolidation. The proposed amendments in this Update would affect all reporting entities that are required to evaluate whether they should consolidate another entity. The proposed amendments are expected to most significantly affect the financial reporting of entities that are involved with variable interest entities.

2/10/12 - Comments on a proposed accounting standards update of Topic 946, Financial Services—Investment Companies. The amendments in this proposed Update would affect the scope, measurement, presentation, and disclosure requirements for investment companies in U.S. generally accepted accounting principles (GAAP).

1/25/12 - Comments on an exposure draft of a proposed statement on auditing standards (SAS). The proposed SAS would supersede SAS No. 59, The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern, as amended (AICPA, Professional Standards, AU sec. 341 and AU-C sec. 570), and represents the redrafting of SAS No. 59 to apply the Auditing Standards Board’s clarity drafting conventions.

1/19/12 - The Professional Ethics Executive Committee (PEEC) is exposing for comment two new interpretations under Rule 505, Form of Organization and Name (AICPA, Professional Standards, ET sec. 505 par. .01). Proposed Interpretation No. 505-4, “Misleading Firm Names,” and proposed Interpretation No. 505-5, “Use of a Common Brand Name in Firm Name,” provide guidance on when firm names would be considered misleading. Also, The PEEC is recommending Ethics Ruling No. 134, “Association of Accountants Not Partners,” of ET section 591, Ethics Rulings on Other Responsibilities and Practices (AICPA, Professional Standards, ET sec. 591, par. .267), be deleted because the guidance contained in proposed Interpretation No. 505-4, “Misleading Firm Names,” would provide members with guidance on misleading firm names.

1/4/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-007, proposed amendments to PCAOB standards that would: (1) require registered public accounting firms to disclose the name of the engagement partner, (2) amend the Annual Report Form to require firms to disclose the name of the engagement partner for each audit report already required to be reported on the form, and (3) require disclosure in the audit report of other independent public accounting firms and other persons that took part in the audit.

12/13/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-006, a concept release to solicit public comment on ways that auditor independence, objectivity and professional skepticism could be enhanced, including the possible approach of mandatory audit firm rotation.

12/12/11 - The NYSSCPA President’s letter to the FAF acknowledging the need to improve the financial reporting of private companies calling for an autonomous standard-setting body to implement differential standards for private companies that is not subject to FASB ratification.

12/6/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to amend the definition of “monetary instrument'' in the Bank Secrecy Act (``BSA'') regulations for purposes of the international transport of currency and monetary instrument reporting requirement to include tangible prepaid access devices.

11/15/11 - Letter to US Congressman Jerome Nadler requesting co-sponsorship and support of H.R. 1864, the Mobile Workforce State Income Tax Simplification Act of 2011.

11/14/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to require electronic filing of Bank Secrecy Act Reports.

10/21/11 - Response to IRS Notice 2011-82 inviting public comments on specific issues which have been identified for consideration in proposed regulations to be issued under section 2010(c).

9/27/11 - Comments on a proposed accounting standards update, the objective of which is to resolve the diversity in practice about whether the guidance in Subtopic 360-20 applies to a parent that ceases to have a controlling financial interest in a subsidiary that is in substance real estate as a result of default on the subsidiary’s nonrecourse debt.

9/27/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-003, a concept release to solicit public comment on the potential direction of a proposed standard-setting project on the content and form of reports on audited financial statements, specifically potential changes to the auditor's reporting model based on concerns of investors and other financial statement users.

9/14/11 - NYSSCPA response to a request by the International Auditing and Assurance Standards Board (IAASB) for comments on a consultation paper that seeks to determine whether there are common views among users of audited financial statements and other stakeholders about the usefulness of auditor reporting.

7/28/11 - Comments on recommendations made by the Blue-Ribbon Panel on Private Company Financial Reporting to the Financial Accounting Foundation regarding differential standards and a separate standard-setting entity for private companies.

7/28/11 - Comments to the Securities and Exchange Commission on an SEC Staff Paper: Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers – Exploring a Possible Method of Incorporation (May 26, 2011).

7/1/11 - Comments to the IRS in response to IRS Notice 2011-48 inviting public comments on the content and administration of the registered tax return preparer competency examination.

6/30/11 - Letter to NYS Governor Andrew M. Cuomo recommending the signing into law of bill A.4881-B/S.2628-A to grant cross-border practice mobility in accordance with Section 23 of the Model Uniform Accountancy Act.

6/6/11 - Comments on a proposed accounting standards update, the objective of which is to simplify how an entity is required to test goodwill for impairment by permitting a qualitative assessment.

5/31/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on a discussion paper that explores issues and perspectives regarding financial statement disclosures and auditing disclosures in a financial statement audit.

5/31/11 - Comments to the IRS indicating circumstances in which additional guidance might be beneficial with respect regulations on basis reporting by securities brokers and basis determination for stock (Final Regulations 1.1012-1(c)(10), 1.1012-1(e)(12), 1.6045A-1(d), 1.6045B-1(g)).

5/23/11 - Recommendations to the IRS to improve tax reporting, specifically, recommendations on changes to certain tax filing due dates.

5/23/11 - Comments to the IRS regarding the effect on an S corporation shareholder’s stock basis of prior year losses that were not deductible because of the basis limitation on deductibility of losses.

4/27/11 - Comments on a proposed accounting standards update addressing the differences in the offsetting (netting) requirements in U.S. GAAP and IFRSs.

4/27/11 - Response to an invitation to comment, issued by the FASB and IASB, on their discussion paper considering how best to improve and simplify standards for financial reporting of financial instruments, and, at the same time, provide users with clearer and more complete information.

4/4/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on the proposed IAASB Strategy and Work Program for 2012 – 2014.

4/1/11 - Comments to the FASB on this Supplementary Document, issued by the FASB as a step preceding the development of an Exposure Draft of a proposed Accounting Standards Update. This supplementary document presents an impairment model that the FASB and IASB believe will enable them to satisfy at least part of their individual objectives for impairment accounting while achieving a common solution to impairment.

2/16/11 - Letter to New York City Department of Finance Commissioner Frankel requesting resumption of the Tax Representatives and Practitioners Program (TaxRAPP), noting its benefit to both practitioners and the department.

2/11/11 - Comments on proposals relating to International Auditing Practice Statements (IAPSs) including withdrawal of existing IAPSs, clarification of the status and authority of new IAPSs, proposed amendments to the Preface to the International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements, and Proposed International Auditing Practice Statement IAPSs 1000, Special Considerations in Auditing Complex Financial Instruments.

2/7/11 - Letter to NYS Governor Andrew M. Cuomo recommending the continuation of the Office of the New York State Taxpayer Rights Advocate, that its role be codified, and suggestions as to its term, reporting, and other aspects.

1/31/11 - Comments to the AICPA on a Proposed Revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country. This proposed revised SAS would supersede SAS No. 51, Reporting on Financial Statements Prepared for Use in Other Countries (AICPA, Professional Standards, vol. 1, AU sec. 534).

1/12/11 - Comments to the FASB on a Proposed Accounting Standards Update – Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements. The objective of the proposed update is to improve the accounting for repurchase agreements (repos) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity.

10/22/10 - Comments to the FASB on a Proposed Accounting Standards Update – Revenue Recognition (Topic 605) Revenue from Contracts with Customers. The proposed guidance, part of joint FASB and IASB effort to clarify revenue recognition principles, specifies the principles that an entity would apply to report information about revenue and cash flows arising from its contracts to provide goods or services to customers.

10/8/10 - Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede paragraph 5 of SAS No. 116, Interim Financial Information (AICPA, Professional Standards, vol. 1, AU sec. 722).

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments (Topic 825) and Derivatives and Hedging (Topic 815): Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. The objective of the proposed Update is to provide financial statement users with a more timely and representative depiction of an entity’s involvement in financial instruments, while reducing the complexity in the accounting.

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Comprehensive Income (Topic 220): Statement of Comprehensive Income. The amendments in this proposed Update would require that all components of comprehensive income be reported in a continuous financial statement that displays the components of net income and the components of other comprehensive income within comprehensive income.

9/28/10 - Letter to the NYS Congressional Delegation requesting action to repeal section 9006, which imposes unreasonably burdensome Form 1099 reporting requirements on all business taxpayers, particularly on small businesses.

9/28/10 - Comments to the IRS regarding new requirements with respect to the reporting of payments made in the course of a payor’s trade or business. The new requirements are in IRC Section 6041, which was amended by section 9006 of the Patient Protection and Affordable Care Act of 2010. Very generally, the amendments expand existing information reporting requirements (generally on form 1099) to apply to payments made to corporations and to include certain payments of gross proceeds and with respect to property.

9/13/10 – Comments to the Public Company Accounting Oversight Board on Release No. 2010-003 (Docket No. 028), a proposed auditing standard which would supersede the Board's standard, AU section 330, The Confirmation Process, and related amendments to the Board's auditing standards.

9/13/10 – Comments to the New York State Board for Public Accountancy of the New York State Education Department on proposed new Section 70.10 of the Regulations of the Commissioner of Education to establish a mandatory quality review program for the profession of public accountancy.

9/9/10 - Comments to the SEC on interactive data to improve financial reporting with observations obtained from the implementation of the Extensible Business Reporting Language (XBRL).

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Fair Value Measurements and Disclosures (Topic 820): Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs. This proposed Update is a result of the continuing efforts of the FASB and the IASB to develop common requirements for measuring fair value and for disclosing information about fair value measurements.
 

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Plan Accounting—Defined Contribution Pension Plans (Topic 962): Reporting Loans to Participants by Defined Contribution Pension Plans. The objective of the proposed Update is to clarify how loans to participants should be classified and measured by defined contribution pension benefit plans.
 

8/31/10 – Comments to the AICPA’s Peer Review Board on their exposure draft of proposed revisions to the standards for performing and reporting on peer reviews, specifically the process used to evaluate quality control materials (QCM) and continuing professional education (CPE) programs and guidance and independence concerns for those involved in the development and maintenance of QCM or CPE programs.
 

8/27/10 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposed revisions to the Bank Secrecy Act regulations applicable to Money Services Businesses with regard to stored value or prepaid access payment methods.

 

 

8/20/10 - Comments to the FASB on a Proposed Accounting Standards Update: Receivables (Topic 310) – Disclosure of Certain Loss Contingencies. To improve adequacy and timeliness of information in assessing the likelihood, timing, and magnitude of future cash outflows associated with loss contingencies

 

  • Comments to the IASB on an Exposure Draft – Financial Instruments: Amortised Cost and Impairment

    6/28/10 - Comments on an IASB exposure draft representing the second phase of a project to replace IAS 39 Financial Instruments: Recognition and Measurement, the stated objective of which is to improve the decision-usefulness of financial statements for users by improving amortised cost measurement, in particular the transparency of provisions for losses on loans and for the credit quality of financial assets.

    4/27/10 – Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede SAS No. 73, Using the Work of a Specialist (AICPA, Professional Standards, vol. 1, AU sec. 336) and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    8/7/09 - Comments on IASB's exposure draft of proposals to improve the derecognition requirements for financial instruments in IAS 39 and enhance disclosure requirements regarding an entity’s exposure to the risks of transferred financial assets.

    7/17/09 – Comments on an exposure draft of a proposed statement on auditing standards on subsequent events. This proposed SAS would supersede SAS Nos. 1 and 58 and AU sections 530, 560 and 561, and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    7/2/09 – Comments on FASB's proposed FSP 157-g that would amend FASB Statement No. 157, Fair Value Measurements, to provide application guidance for estimating the fair value of investments in investment companies that have calculated net asset value per share in accordance with the AICPA Audit and Accounting Guide, Investment Companies.

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards on initial audit engagements, including reaudits – opening balances. This proposed SAS would supersede SAS No. 84, Communications Between Predecessor and Successor Auditors and represents a redrafting of SAS No. 84 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on a Proposed Statement on Auditing Standards – Consideration of Laws and Regulations in an Audit of Financial Statements

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede SAS No. 54, Illegal Acts by Clients and represents the inclusion of comments by the Auditing Standards Board’s clarity drafting conventions and convergence with International Standards on Auditing.

    5/29/09 – Comments on an exposure draft of a proposed statement on auditing standards on audit sampling. This proposed SAS represents the redrafting of SAS No. 39, Audit Sampling to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA and CICA on Exposure Draft - Generally Accepted Privacy Principles

    5/29/09 – Comments to the AICPA and Canadian Institute of Chartered Accountants (CICA) on their exposure draft of generally accepted privacy principles designed to be used as an operational framework to manage privacy risks.

    2/12/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede Statement on Auditing Standards No. 70, Service Organizations, which contains guidance for auditors auditing the financial statements of entities that use a service organization and for auditors reporting on controls at a service organization.

    2/11/09 – Comments to the Public Company Accounting Oversight Board on Release No. 2008-006, specifically addressing Appendix 4, The Auditor's Responses to the Risks of Material Misstatement, page A4–13–37.

9/29/08 - NYSSCPA response to FASB’s Invitation to Comment –Preliminary Views, Conceptual Framework for Financial Reporting: The Reporting Entity.

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 114 (Redrafted), The Auditor’s Communication With Those Charged with Governance, that would supersede existing SAS No. 114. The proposed SAS represents the redrafting of SAS No. 114 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on Proposed Statement on Auditing Standards No. 103 (Redrafted), Audit Documentation

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 103 (Redrafted), Audit Documentation, that would supersede existing SAS No. 103. The proposed SAS represents the redrafting of SAS No. 103 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    6/30/08 – Comments to the Governmental Accounting Standards Board on their exposure draft of fund balance reporting and governmental fund type definitions.

    12/28/07– Comments on proposed FASB Staff Position (FSP) FAS 157-a – Application of FASB Statement No. 157 to FASB Statement No. 13 and its related interpretive accounting pronouncements that address leasing transactions (issued 11/28/07).

  • Comments to AICPA on Improving the Uniform CPA Examination

    9/21/07 – Comments to the Securities and Exchange Commission on Release No. 33-8818 – Acceptance from Foreign Private Issuers of Financial Statements Prepared in Accordance with International Financial Reporting Standards without Reconciliation to U.S. GAAP.

    11/14/06 – Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their Exposure Draft - Omnibus Proposal of Professional Ethics Division Interpretations and Rulings dated September 8, 2006. Comments are on the Proposed Deletion of Rulings Under Rule 101, and Proposed Revision to Interpretation 101-3 under Rule 101: Performance of Nonattest Services: Forensic Accounting Services and Tax Compliance Services.

  • Comments to FASB on Preliminary Views - Conceptual Framework for Financial Reporting

    8/3/06 – Comments to GASB on its preliminary views document regarding the accounting and financial reporting for derivatives in government-wide and fund financial statements.

    1/27/06 – Comments to AICPA Professional Ethics Executive Committee on Proposed Omnibus Proposal: Proposed Interpretation 101-17, Performance of Client Advocacy Services, Fact Witness Testimony, and Forensic Accounting Services, Under Rule 101, Independence, dated September 15, 2005

1/13/06 – Response to the Committee of Sponsoring Organizations’ (COSO) request for comment on their exposure draft of proposed Guidance for Smaller Public Companies Reporting on Internal Control over Financial Reporting.

    11/2/05 – Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of a proposed Statement on Auditing Standards entitled “Communication of Internal Control Related Matters Noted in an Audit.” The proposed standard is intended to strengthen the communication of internal control related matters for non-issuer entities.

    3/4/05 – Response to request from the NY State CFR Interagency Committee for advice on options for the reporting of sales of management services on the consolidated fiscal report.

  • Comments on PCAOB Release No. 2004-015 – Proposed Ethics and Independence Rules

    2/22/05 – Comments on PCAOB Release No. 2004-015 – Proposed Ethics and Independence Rules concerning Independence, Tax Services, and Contingent Fees.

    1/20/04 Society’s comments to the PCAOB regarding its proposed rules on audit documentation and amendment to interim auditing standards, and suggestion to incorporate a glossary of terms.

  • Recommendations on NYC Form TC 201

    11/21/03 - Comments on the Public Company Accounting Oversight Board’s exposure draft of proposed rules that would integrate the audits of internal control over financial reporting with the audits of financial statements.

    9/15/03 - Society’s response to Treasury’s request for comments on proposed regulations relating to the assumption of and definition of liabilities under section 752 of the Internal Revenue Code.

    8/1/03 - Society’s respone to the AICPA’s request for comments regarding the recently issued exposure draft on proposed revisions to the AICPA Standards for Performing and Reporting on Peer Reviews.

  • Comments on AICPA Professional Ethics Executive Committee Exposure Draft

    5/31/03 - Comments on the AICPA PEEC Exposure Draft: Omnibus Proposal of Professional Ethics Division Interpretations and Rulings, March 19, 2003

  • Comments on Tax Simplification

    5/27/03 - NYSSCPA strongly urges Congress to address simplification issues either in IRS regulations or in future legislation.

    A specially appointed NYSSCPA task force identifies the more egregious areas of the Internal Revenue Code that are eligible for simplification, outlines why they are complex and offers solutions to assure proper compliance.

    4/23/03 - Comments on Attorney General Eliot Spitzer's proposed legislation for governing not-for-profit organizations in New York State.

    1/17/03 - Specific comments on this proposed International Auditing Practice Statement (IAPS) of the International Federation of Accountants (IFAC) for Reporting on Compliance with International Financial Reporting Standards.

    7/9/02 - Society comments on a FASB exposure draft dealing with the accounting for derivatives and hedging.

    7/9/02 - Society comments on an ASB exposure draft dealing with one of the most important issues that the O'Malley Panel identified for auditors, the consideration of fraud in a financial statement audit.

    6/26/02 - Society comments on the proposed amendment to SAS 50, which would prohibit an accountant from providing a written report on the application of accounting principles not involving facts and circumstances of a specific entitiy (hypothetical trasnsactions).