Overview
Title
Proposed Collection; Comment Request for Revenue Procedure 99-17
Agencies
ELI5 AI
The IRS wants people to tell them if their way of asking traders for information is useful and easy to understand, aiming to make it less of a hassle for everyone.
Summary AI
The Internal Revenue Service (IRS) is seeking comments from the public and other federal agencies about the "Mark to Market Election" for commodities dealers and securities and commodities traders. This is part of an effort to reduce paperwork and respondent burden. The IRS requests feedback on the necessity, accuracy, and improvement of the information collection process required by this revenue procedure. Comments must be submitted by March 18, 2025, and will influence future approval processes.
Abstract
The Internal Revenue Service (IRS), as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on information collections, as required by the Paperwork Reduction Act of 1995. The IRS is soliciting comments concerning, Mark to Market Election for Commodities Dealers and Securities and Commodities Traders.
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AnalysisAI
The document titled "Proposed Collection; Comment Request for Revenue Procedure 99-17" is a Notice from the Internal Revenue Service (IRS), inviting comments from the general public and other federal agencies on the information collection regarding the "Mark to Market Election" for commodities dealers and securities and commodities traders. This initiative relates to the IRS's ongoing efforts to minimize paperwork and reduce the burden on those required to respond.
General Summary
The Notice, published on January 17, 2025, outlines the IRS's request for feedback on several aspects of the information collection, such as its necessity, the accuracy of their burden estimates, and suggestions for improvement. The deadline for submitting comments is March 18, 2025. The overall aim is to refine and potentially extend a previously approved collection process related to this specific election under Revenue Procedure Series, notably the mark-to-market accounting methods.
Significant Issues or Concerns
One of the primary concerns is the lack of detailed elaboration regarding specific strategies the IRS will employ to achieve the stated goal of reducing paperwork and burden. While the notice mentions these objectives, it does not provide concrete proposals or examples. Additionally, the rationale for estimating the number of respondents at 1,000 and the average time of 30 minutes per respondent lacks detailed explanation, leaving room for speculation on their accuracy.
The document also invites public comment on several points but does not guide readers on potential directions for improving the clarity and utility of the information collection. Furthermore, there is no specific mention of additional measures to ensure taxpayer confidentiality beyond broad references to existing laws like 26 U.S.C. 6103.
Impact on the Public Broadly
The call for public comments provides an opportunity for individuals and organizations to participate in shaping the information collection process. By contributing feedback, the public can help ensure that the process is effective, less burdensome, and more aligned with practical realities. However, the potential impact of this engagement is contingent upon the IRS's responsiveness to the feedback received and its willingness to implement suggested improvements.
Impact on Specific Stakeholders
For businesses, particularly those involved in commodities and securities trading, this proposed collection might affect how they report and account for their financial activities. By informing the IRS's approach, traders and dealers could benefit from streamlined processes that reduce administrative overhead, provided their input leads to meaningful change.
Conversely, without clear guidance or rationale for existing estimates and strategies, these stakeholders may remain concerned over the requirements' effectiveness and resource demands. Ensuring their concerns and suggestions are heard and translated into action is vital for positive stakeholder impact.
In conclusion, while the IRS's effort to gather feedback as part of its procedural oversight is commendable, deeper insight into the processes and assurances of action may pave the way for more impactful results. Stakeholders and the public alike would benefit from more detailed procedural transparencies and reassurances on confidential information handling.
Issues
• The document doesn't specify if there are any specific organizations or individuals who disproportionately benefit from the proposed changes in information collection.
• There is no detailed explanation of why the estimated number of respondents is 1,000 and why the estimated time per respondent is 30 minutes. Additional justification for these numbers would enhance clarity.
• The abstract mentions reducing paperwork and respondent burden but does not provide detailed strategies on how this will be achieved.
• The document invites public comment on several points but does not suggest possible methods for improving the clarity and utility of the information collection process.
• No mention of specific measures that will be taken to safeguard taxpayer confidentiality beyond referencing 26 U.S.C. 6103.
• The summary section repeats information present in other sections, such as the purpose of the solicitation of comments, which could be more concisely referenced.