Treasury and IRS 2026-2027 Priority Guidance Plan

Published on: by Gene Takagi Category:IRS & FEDERAL TAX ISSUES
U.S. Treasury Department building in Washington DC on an overcast day

The joint Treasury and IRS Initial 2026-2027 Priority Guidance Plan was released on September 29, 2026. The Plan contains 121 guidance projects that are priorities for allocating Treasury Department and IRS resources during the 12-month period from October 1, 2026, through September 30, 2027. These projects reflect their focus on the following key areas: continued implementation of the One, Big, Beautiful Bill Act; deregulation and burden reduction; and guidance addressing tax exempt organizations, Tribal tax issues, digital assets, and other priorities. Treasury and the IRS may modify the Plan during the Plan year.

The following are some of the projects that may be of importance to tax-exempt organizations (all section references are to the Internal Revenue Code):

ONE, BIG, BEAUTIFUL BILL ACT IMPLEMENTATION

1. Regulations under §25F on the income tax credit for contributions of individuals to scholarship granting organizations.

12. Guidance under §§128, 139J, 530A, 6434, and 6659 regarding Trump accounts. Proposed regulations were published on March 9, 2026, August 11, 2026, and August 21, 2026.

25. Guidance under §529 regarding enhancements to qualified tuition programs.

26. Guidance under §530 on qualified elementary and secondary education expenses.

34. Regulations under §2010 regarding extension and enhancement of increased estate and gift tax exemption amounts and related issues.

36. Regulations under §4960 regarding excess compensation paid by applicable tax-exempt organizations, including the expanded definition of “covered employee.”

37. Regulations under §4968 regarding excise tax based on investment income of certain private colleges and universities.

DEREGULATION AND BURDEN REDUCTION

42. Regulations under §4945 regarding expenditure responsibility requirements.

47. Final regulations concerning the reporting of charitable contributions of trusts under §6034. Proposed regulations were published on August 17, 2026.

48. Regulations under §6104 regarding the place for public inspection of materials relating to tax-exempt organizations, pensions, and other plans.

TAX EXEMPT ORGANIZATIONS

1. Final regulations regarding the application of the fundamental public policy against racial discrimination, including consideration of recent caselaw, in determining the eligibility of private schools for recognition of tax-exempt status under §501(c)(3). Proposed regulations were published on September 4, 2026.

2. Guidance on the statutory prohibition in §501(c)(3) against participation or intervention in political campaigns (the “Johnson Amendment”).

3. Guidance revising Rev. Proc. 2026-08 for certain types of group exemption letters.

4. Guidance under §§4966 and 6033 regarding certain donor advised fund arrangements.

5. Guidance under §6033 regarding exempt organization information reporting requirements, including with regard to fiscal sponsorship arrangements.