IRS Priority Guidance Plan for 2023-2024—exempt organization projects
Tax issues to be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance
Tax issues to be addressed through regulations, revenue rulings, revenue procedures, notic
The U.S. Treasury Department and IRS today released the 2023-2024 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 2023-2024 Priority Guidance Plan [PDF 272 KB] contains 237 guidance projects that are priorities for allocating Treasury and IRS resources during the 12-month period from July 1, 2023 through June 30, 2024. Of these projects, nine have been released or published as of August 31, 2023.
The Treasury Department and IRS also released the fourth quarter update [PDF 585 KB] (August 21, 2023) of the 2022-2023 Priority Guidance Plan, which indicates which of the priority guidance projects and other guidance projects were completed during the 12-month period from July 1, 2022 through June 30, 2023.
During the 2022-2023 plan year, only one of the priority guidance plan items under the exempt organizations heading was completed, namely the publication on August 16, 2022, of final regulations under section 6104(c), relating to information sharing with state charity officials. This year’s exempt organizations list includes all of the remaining projects from last year’s list, as well as a new item promising guidance relating to changes made by the “SECURE 2.0 Act” to section 529.
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 addressing the “SECURE 2.0 Act” changes relating to section 529.
- Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners.
- Regulations under section 4966 regarding donor advised funds, including excise taxes on sponsoring organizations and fund management.
- Regulations under section 4967 regarding prohibited benefits, including excise taxes on donors, donor advisors, related persons, and fund management.
- Regulations under section 4958 regarding donor advised funds and supporting organizations.
- Guidance regarding the public-support computation with respect to distributions from donor advised funds.
- Regulations designating an appropriate high-level Treasury official under section 7611. Proposed regulations were published on August 5, 2009.
Additionally, exempt organizations may also have interest in guidance projects relating to tax-exempt bonds and charitable contributions. With respect to the latter, last year the IRS published proposed regulations on December 8, 2022, relating to the listing of syndicated conservation easement transactions, and Notice 2023-30 on April 10, 2023, relating to conservation easement contributions. This year, the guidance plan continues to list two charitable contribution guidance projects and has seven tax-exempt bonds guidance projects (two newly added this year).
Charitable giving projects listed under the heading “General Tax Issues”
- Guidance under section 170 regarding charitable contributions.
- Guidance under section 170 regarding conservation easements, including facade easements.
Projects listed under the heading “Tax-exempt Bonds”
- Guidance under section 142, as amended by the “Infrastructure Investment and Jobs Act.”
- Revenue procedure providing guidance on the use of average area purchase prices and median income figures for purposes of section 143.*
- 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.
- Regulations under section 149 to update requirements for certain tax-exempt bond information returns.*
- Final regulations on bond reissuance under section 150. Proposed regulations were published on December 31, 2018.
Treasury and the IRS in May 2023 solicited recommendations for items to be included in the plan. Read TaxNewsFlash
* New addition for 2023-2024
For more information, contact your usual KPMG tax professional or one of the following Washington National Tax professionals:
Ruth Madrigal | ruthmadrigal@kpmg.com
Preston Quesenberry | pquesenberry@kpmg.com
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