IRS Priority Guidance Plan 2022-2023—exempt organization projects increase focus on DAFs

Tax issues to be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance

Exempt organization projects increase focus on DAFs

The U.S. Treasury Department and IRS today released the 2022-2023 Priority Guidance Plan.

The Priority Guidance Plan is used each year to identify and prioritize tax issues to be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance.

The 2022-2023 Priority Guidance Plan [PDF 245 KB] identifies guidance projects that the IRS and Treasury Department intend to work on as priorities during the 12-month period from July 1, 2022, through June 30, 2023. There are 205 guidance projects on the 2022-2023 priority guidance plan.

Treasury and the IRS in April 2022 solicited recommendations for items to be included in the plan. Read TaxNewsFlash

Projects listed under the heading “Exempt Organizations”

  • Guidance revising Rev. Proc. 80-27 regarding group exemption letters. Notice 2020-36 was published on May 18, 2020.
  • Final regulations on section 509(a)(3) supporting organizations. Proposed regulations were published on February 19, 2016.
  • Regulations under section 512 regarding the allocation of expenses in computing unrelated business taxable income and addressing how changes made to section 172 net operating losses by section 2303(b) of the CARES Act apply for purposes of section 512(a)(6).
  • Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners.
  • Guidance relating to designation of an appropriate high level Treasury official under section 7611.
  • Four items relating to donor advised funds (DAFs), including regulations under sections 4966, 4967 and 4958 regarding excise taxes on donor/advisors, sponsoring organizations and fund management, and guidance relating to the public-support computation with respect to distributions from donor advised funds.

Projects listed under the heading “Tax-exempt Bonds”

  • Guidance under section 142, as amended by the Infrastructure Investment and Jobs Act.
  • Guidance under sections 144(b) and 150 on qualified student loan bonds.
  • Regulations under sections 148 and 150 on refunding bonds.
  • Revenue procedure on the recovery of rebate under section 148.
  • Final regulations on bond reissuance under section 150. Proposed regulations were published on December 31, 2018.

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal |

Preston Quesenberry |


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