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Letter to TAX on pass-through entity tax guidelines

July 8, 2022 

James Ford 
Tax Commissioner 
Virginia Department of Taxation 
P. O. Box 546 
Richmond, VA 23218-0546 

Via email: [email protected] 

RE: Elective Pass-Through Entity Tax Guidelines 

Dear Mr. Ford: 

The Virginia Society of Certified Public Accountants (VSCPA) Tax Advisory Committee is responding to the request for comments regarding the Elective Pass-Through Entity Tax Guidelines being developed in response to HB 1121 and SB 692 as passed during the 2022 Session of the Virginia General Assembly. 

The Committee appointed a special task force comprised of members who work with pass-through entity tax issues to provide feedback and recommendations on implementation of this legislation. The task force’s feedback (PDF) is attached. The feedback is based on experience with implementation of similar  provisions in other states as well as the questions the VSCPA has already been receiving from members. 

The Virginia Society of Certified Public Accountants (VSCPA) is the leading professional association in the Commonwealth dedicated to empowering CPAs to thrive. Founded in 1909, the VSCPA has more than 13,000 members who work in public accounting, industry, government and education. Please feel free to contact me or VSCPA Vice President, Advocacy Emily Walker, CAE, at (804) 612-9428 or [email protected] if we can be of further assistance. 


Sarah Adams, CPA Chair, 2022–2023 Tax Advisory Committee 
Virginia Society of CPAs 

CC: Kristin Collins — Assistant Commissioner, Tax Policy
       Patrick Cushing —  VSCPA Legislative Counsel