On 8 November 2018, the US Treasury and IRS published its 2018–2019 Priority Guidance Plan, detailing tax guidance the government intends to focus its effort on in the coming months. The Guidance Priority List focuses resources on guidance items that are most important to taxpayers and tax administration. Published guidance plays an important role in increasing voluntary compliance by helping to clarify ambiguous areas of the tax law.

The 2018-2019 Priority Guidance Plan contains guidance projects that will be the focus of efforts during the twelve-month period from July 1, 2018, through June 30, 2019 (the plan year). The 2018-2019 Priority Guidance Plan contains 239 guidance projects, for which 45 items have been released as of October 31, 2018. In addition to the projects on the 2018-2019 plan, the Appendix lists routine or ministerial guidance that is generally published each year.

The new items added to the priority list are as follows:

• Regulations under new §59A concerning the base-erosion and anti-abuse tax.
• Regulations concerning the participation exemption system for the taxation of
  foreign source income under §§245A, 1248(j) and (k), and 91.
• Regulations under new §250 regarding the deduction for foreign derived
  intangible income and global intangible low-taxed income.
• Regulations under new §267A addressing certain related-party amounts paid or accrued in hybrid transactions or by or to hybrid entities.
• Regulations addressing the changes to §§367(d) and 482 under the TCJA.
• Regulations on certain foreign tax credit issues arising under the TCJA under §§901, 960, 78, and related provisions.
• Regulations under new §951A regarding the inclusion of global intangible low taxed income by United States shareholders.