IRS Priority Guidance Plan for 2024-2025—exempt organization projects

The U.S. Treasury Department and IRS today released the 2024-2025 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 2024-2025 Priority Guidance Plan contains 231 guidance projects that are priorities for allocating Treasury and IRS resources during the 12-month period from July 1, 2024, through June 30, 2025. Of these projects, 17 have been released or published as of August 31, 2024.

Treasury and the IRS in March 2024 solicited recommendations for items to be included in the plan. Read TaxNewsFlash

The plan adds one new guidance project specifically applicable to exempt organizations: Guidance illustrating the application of the regulations under section 501(r). Section 501(r) imposes requirements on hospital organizations described in section 501(c)(3). The IRS is currently engaged in a compliance strategy focused on verifying compliance with section 501(r).

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.
• Guidance illustrating the application of the regulations under section 501(r).
• 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.
• Final regulations under section 4966 regarding donor advised funds, including excise taxes on sponsoring organizations and fund management. Proposed regulations were published on November 14, 2023.
• 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.
• Final regulations designating an appropriate high-level Treasury official under section 7611. Proposed regulations were published on August 5, 2009.

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.
• Guidance under section 7701 providing criteria for treating an entity as an integral part of a State or local government, and guidance on federally and tribally chartered Tribal entities.

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.
• 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.

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