The Treasury Department and the IRS are asking stakeholders to submit recommendations on items that should be included in the agency’s 2026-2027 Priority Guidance Plan.
The plan is used by the IRS and Treasury Department’s Office of Tax Policy to identify and prioritize tax issues that can be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance.
The projects deemed to be a priority would be worked on during the period from July 1, 2026, through June 30, 2027.
“The Treasury Department and the IRS recognize the importance of public input in formulating a Priority Guidance Plan that focuses resources on guidance items that are most important to taxpayers and tax administration,” the IRS said in Notice 2026-23, which was issued on March 23. “Published guidance plays an important role in increasing voluntary compliance by helping to clarify ambiguous areas of the tax law. The published guidance process is most successful if the Treasury Department and the IRS have the benefit of the experience and knowledge of taxpayers and practitioners who must apply the rules implementing the tax laws.”
In reviewing recommendations and selecting additional projects for inclusion in the 2026-2027 Priority Guidance Plan, the Treasury Department and the IRS said they will consider the following:
1. Whether the recommended guidance relates to recently enacted legislation, such as Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One Big Beautiful Bill Act.
2. Whether taxpayers have identified that the recommended guidance relates to regulations potentially described in Executive Order 14219 (90 FR 10583) Section 2(a):
- Unconstitutional regulations and regulations that raise serious constitutional difficulties, such as exceeding the scope of the power vested in the federal government by the Constitution;
- Regulations that are based on unlawful delegations of legislative power;
- Regulations that are based on anything other than the best reading of the underlying statutory authority or prohibition;
- Regulations that implicate matters of social, political, or economic significance that are not authorized by clear statutory authority;
- Regulations that impose significant costs upon private parties that are not outweighed by public benefits;
- Regulations that harm the national interest by significantly and unjustifiably impeding technological innovation, infrastructure development, disaster response, inflation reduction, research and development, economic development, energy production, land use, and foreign policy objectives; and
- Regulations that impose undue burdens on small business and impede private enterprise and entrepreneurship.
3. Whether the recommendation involves existing regulations or other guidance that is outdated, unnecessary, ineffective, insufficient, or unnecessarily burdensome and that should be modified, streamlined, expanded, replaced, or withdrawn.
4. Whether the recommended guidance reduces controversy and lessens the burden on taxpayers or the IRS.
5. Whether the recommended guidance would be in accordance with Executive Order 14192 (90 FR 9065) or other executive orders.
6. Whether the recommended guidance resolves significant issues relevant to a broad class of taxpayers.
7. Whether the recommended guidance promotes sound tax administration.
8. Whether the IRS can administer the recommended guidance on a uniform basis.
9. Whether the recommended guidance can be drafted in a manner that will enable taxpayers to easily understand and apply the guidance.
Stakeholders have until May 29 to submit recommendations for guidance that could be included in the upcoming plan. The IRS strongly encourages recommendations be sent electronically via the Federal eRulemaking Portal at www.regulations.gov. Type “IRS-2026-0364” in the search field on the homepage to find Notice 2026-23 and submit recommendations.
The notice also provides instructions on how to submit recommendations by mail.
“Taxpayers are not required to submit recommendations for guidance in any particular format,” the IRS said. “Taxpayers should, however, briefly describe the recommended guidance and explain the need for the guidance. In addition, taxpayers may include an analysis of how the issue should be resolved. For recommendations to modify, streamline, or withdraw existing regulations or other guidance, taxpayers should explain how the changes would reduce taxpayer cost and/or burden or benefit tax administration. It would be helpful if taxpayers suggesting more than one guidance project prioritize the projects by order of importance. If a large number of projects are being suggested, it would be helpful if the projects were grouped by subject matter and then in terms of high, medium, or low priority. Requests for guidance in the form of petitions for rulemaking will be considered with other recommendations for guidance in accordance with the considerations described in this notice.”
Photo credit: HABesen/iStock
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Tags: IRS, Taxes, Treasury Department
