The US Internal Revenue Service and Treasury Department have issued Notice 2026-23, inviting taxpayers and practitioners to submit recommendations for the 2026–2027 Priority Guidance Plan. Submissions will help shape guidance on tax regulations, rulings, and procedures for the year starting 1 July 2026.
The US Internal Revenue Service (IRS) and Department of the Treasury released Notice 2026-23 on 23 March 2026, inviting public recommendations for items to be included in the 2026–2027 Priority Guidance Plan.
The Priority Guidance Plan is used annually by the Treasury’s Office of Tax Policy and the IRS to identify and prioritise tax issues that require attention through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. The plan outlines the guidance projects that the Treasury and IRS intend to work on actively between 1 July 2026 and 30 June 2027.
In reviewing submissions and selecting projects for inclusion, the Treasury and IRS will consider several factors:
- Relevance to Recent Legislation: Whether the recommended guidance relates to newly enacted laws, such as Public Law 119-21, the “One, Big, Beautiful Bill Act” (4 July 2025).
- Constitutional and Regulatory Concerns: Whether guidance relates to regulations identified in Executive Order 14219 (90 FR 10583) Section 2(a), including regulations that:
- Exceed constitutional authority or involve unlawful delegations of legislative power.
- Deviate from the best reading of the underlying statutory authority.
- Affect matters of social, political, or economic significance without clear statutory authorisation.
- Impose significant costs on private parties not justified by public benefits.
- Unduly impede technological innovation, infrastructure, disaster response, economic development, energy production, or foreign policy objectives.
- Burden small businesses and hinder private enterprise.
- Outdated or Burdensome Guidance: Recommendations involving guidance that is outdated, unnecessary, ineffective, or excessively burdensome, which may need modification, streamlining, expansion, replacement, or withdrawal.
- Reducing Controversy and Burden: Guidance that lowers disputes and lessens compliance burdens on taxpayers or the IRS.
- Alignment with Executive Orders: Recommendations consistent with Executive Order 14192 or other relevant executive orders.
- Broad Impact: Guidance addressing significant issues relevant to a wide class of taxpayers.
- Promotion of Sound Tax Administration: Guidance that supports effective and fair tax administration.
- Uniform Administration: Guidance that can be applied consistently by the IRS.
- Clarity and Accessibility: Guidance that taxpayers can understand and apply easily.
The Treasury and IRS request that recommendations be submitted by Friday, 29 May 2026, for possible inclusion in the original 2026–2027 plan. However, submissions may be made at any time during the year. The plan will be updated periodically to reflect additional guidance projects as they arise.
Submissions do not require a specific format but should briefly describe the recommended guidance, explain its necessity, and may include analysis on how to resolve the issue. Recommendations to modify or withdraw existing guidance should outline how changes would reduce taxpayer costs or burdens, benefit tax administration, or address issues identified in Executive Order 14219 Sections 2(a)(i)–(vii).
Taxpayers suggesting multiple projects are encouraged to prioritise them and, if numerous, group them by subject and priority level.
Petitions for rulemaking will be considered alongside other recommendations under the same criteria.
