Dear President Biden:

The undersigned organizations representing a cross-section of business and financial interests write to reiterate our strong opposition to the new tax reporting regime proposed by the Department of the Treasury and being considered by Congress as part of the government’s spending program. proposed reconciliation. We respectfully request that this proposal be withdrawn from further consideration and that the administration consider more targeted measures to reduce the tax gap.

Our member companies understand that this proposal is a good faith attempt by your administration to ensure that all taxpayers meet their tax obligations, and we strongly support this goal. However, our members, and the American people, believe they have a reasonable right to privacy, and this overbroad proposal to report gross annual inflows and outflows from almost all accounts is disconnected from its alleged narrow focus of focusing on government review of Americans with incomes over $ 400,000.

This week, the Treasury Department and Congressional supporters finally admitted the program was far too broad but, according to media reports, only made cosmetic changes by raising the de minimis threshold to $ 10,000 and excluding wages and government benefits from this calculation. As we have noted in several previous letters, these changes ignore the fact that any program based on gross annual inflows and outflows will impact Americans of all income levels. Even with the proposed exclusions of certain types of income, a large number of routine and completely innocent transactions by individuals and small businesses will be affected by this new regime.

The privacy concerns of Americans who pay their taxes and who would be dragged into this reporting program are real and should not be taken lightly. Financial institutions are already facing difficult questions from customers regarding this proposal. According to the Treasury Department, it only plans to use the data to increase audits for those earning more than $ 400,000 a year. The likely question for any U.S. taxpayer earning less than that is: why does the IRS need my account information if it isn’t using it?

Basically, this program, which has not been the subject of a meaningful study or detailed review to show the impact on consumers, will collect financial “metadata” on nearly all Americans in the hope. that the IRS will be able to discern trends in aggregate numbers that do not match. tax debts and target audits only on those who break the law. This is a substantial extension of the IRS’s authority that, once established, is sure to expand rather than roll back.

We urge the Administration to withdraw this reporting regime and consider how the IRS can use its existing powers to focus directly on taxpayers suspected of evading their taxes instead of casting such a wide net.

Thank you for considering our point of view, and we are ready to provide more details on our specific concerns at any time.


ACA International

Association of Agricultural Retailers

AICC, the independent packaging association

Air Conditioning Contractors of America

American Federation of Agricultural Offices

American Bankers Association

American Council of Engineering Companies

American Financial Services Association

American Hospitality and Accommodation Association

American Land Titles Association

American Lighting Association

American Association of Mold Builders

American Rental Association

American SBDC

Angel Capital Association

Asian American Hotel Owners Association

Builders and associated contractors

Associated equipment distributors

Automobile maintenance association

Commercial Food Equipment Services Association

Association of Community Development Bankers

Construction industry roundtable

Consumer Bankers Association

Local distribution association

National Association of Credit Unions

Decorative hardwood association

Energy Marketers of America

Family Business Coalition

International Financial Managers

Association of gas and welding distributors

Global Cold Chain Alliance

Hardwood Federation

International heating, air conditioning and refrigeration distributors


Association of Independent Bakers

Independent Community Bankers of America

Independent electrical contractors

Independent Insurance Agents and Brokers of America

Association of Independent Lubricants Manufacturers Institute of Industrial Fasteners

Association of innovative lending platforms

Association of innovative payments

Institute of Scrap Metal Recycling Industries

International Association of Foodservice Distributors

International Franchise Association

International Warehouse Logistics Association

Main street employers

Prefabricated Housing Institute

Metals Service Center Institute

Coalition of Mid-Sized American Banks

Mortgage Bankers Association

Association of Engine and Equipment Manufacturers

National Association of Self-Employed Workers

National Association of Chemical Distributors

National Association of Electricity Distributors

National Association of Federally Insured Credit Unions

National Association of Independent Life Brokerage Agencies

National Association of Industrial Bankers

National Association of Insurance and Financial Advisors National Association of Professional Insurance Agents National Association of Real Estate Agents

National Association of Sporting Goods Wholesalers National Association of Wholesalers-Distributors National Association of Bankers National Association of Beer Wholesalers

National Association of Community Pharmacists

National Cotton Council

National Association of Representatives of Electricity Manufacturers National Federation of Independent Businesses National Association of Grocers

National Association of Independent Automobile Dealers

National Association of Marine Distributors

National Association of Ready-Mixed Concrete

National Association of Roofing Contractors

National Association of RV Dealers

National Association of Small Businesses

National Association of Stone, Sand and Gravel

National Association of Tooling and Machining

North American Association of Food Equipment Manufacturers North American Die Casting Association

Association for the maintenance of motorized equipment and outdoor engines

Association of Pet Industry Distributors

Petroleum Equipment Institute

National Association of Plumbing-Heating-Cooling Contractors

Policy and Taxation Group

Association of precision machined products

Precision Metal Forming Association

Coalition of private investors

International Promotional Products Association

Association of S companies

Small Business and Entrepreneurship Council

Specialized Equipment Market Association

Subchapter S Banking association

The payroll group

The Society of American Florists

Tile Roofing Industry Alliance

Tire Industry Association

Truck Rental and Leasing Association

American Chamber of Commerce


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