VSCPA Task Force Comments on VTAX Regulatory Process

Office of the Commissioner
Post Office Box 1115
Richmond, VA 23218-1115

Re: Guidelines for Public Participation in Regulation Development and Promulgation [23 VAC 10   10]

Dear Commissioner Bowen,

We want to thank you for the opportunity to comment on your proposed regulations regarding the exposure of regulations by the Virginia Department of Taxation (VTAX).

We are writing to you representing the Virginia Society of CPAs (VSCPA) Taxation Advisory Task Force (Task Force). This letter represents the opinion of the expert group only, and does not represent a position of the VSCPA or its membership as a whole.

The Task Force understands the proposed regulation to limit TAX’s announcement and exposure of proposed regulations to take place entirely through the Virginia Town Hall Web site (Town Hall). We applaud TAX’s efforts over the last few years to move toward paperless solutions, as well as the efficiency of online interaction between TAX and its constituency.

However, the Task Force feels that a regulatory review undertaken solely through the Town Hall is premature. From the proposed regulation, it appears that only 687 persons are registered on the Town Hall. There are thousands of tax practitioners in Virginia and countless interested taxpayers, associations and other interested parties who are either not aware of the Town Hall or are not currently registered users.

Although it cannot be incumbent on TAX to ensure that every interested party uses the Commonwealth’s regulatory resources, the Task Force feels as though an educational effort is necessary before eliminating other communication vehicles with those interested parties.

The Task Force suggests TAX take the following actions:

  1. Extend the enactment date (to January 1, 2009, for example).
  2. Place a notice on the TAX Web site to announce TAX’s intention to move to the Town Hall as the sole source of regulatory notification, and include instructions on how to enroll in the Town Hall.
  3. Send one paper and one electronic notice to the list of “interested parties” delineated in 23VAC10-10-20 of the proposed regulations.

Again, we thank TAX for its work in this area and its commitment to moving the agency to more efficient and technologically advanced communications. We ask that you consider our suggestions to make these changes in a manner that will ease that transition for taxpayers and their representatives.

If you have any questions or concerns, please don’t hesitate to contact a member of the Task Force listed below or VSCPA Government Affairs Director Erin Collins at (804) 270-5344.

Thank you again for your consideration.

Sincerely,

VSCPA Taxation Advisory Task Force
    Art Auerbach, CPA: aauerbach@goodmanco.com
    Damon DeSue, CPA: ddesue@dollartree.com
    Rebecca McCoy, CPA: Rebecca.mccoy2007@gmail.com
    Frank Stahl, CPA: man1040@aol.com
    Mark Van Deveer, CPA: markv12@juno.com


Cc: Department of Planning and Budget, Rachel Harrell

LAST UPDATED 2/15/2008

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