Recently, the IRS released a request for recommendations for its 2016-2017 Priority Guidance Plan (PGP). The PGP is the list of issues on which the IRS intends to develop guidance in the upcoming year. For taxpayers, it is a roadmap of where the IRS intends to devote its limited resources in the next year. While unfinished items from the prior year are generally carried over, the addition of new items (or removal of old) can be an early signal of the IRS’s priorities.
Many taxpayers do not realize how important taxpayer engagement is in helping the IRS with the guidance process. This is true of providing input on specific guidance projects, but it is also true of providing input on where the IRS should devote its resources in the upcoming year. Frequently, items identified for the new PGP are driven by new developments, such as court cases or newly-enacted laws, but often ideas come from taxpayers and their representatives regarding issues that they are identifying in their day-to-day operations that could use clearer rules. Taxpayers and the IRS alike benefit from resolving ambiguities that make compliance difficult or uncertain. Organizations encountering tax issues that might be addressed through administrative guidance should consider submitting a recommendation for the PGP.
How can Taxpayers get Involved?
Notice 2016-26 describes the process for submitting recommendations. In particular, Treasury and the IRS are looking for comments on whether:
- The recommended guidance resolves significant issues relevant to many taxpayers
- The recommended guidance promotes sound tax administration
- The recommended guidance can be drafted in a manner that will enable taxpayers to easily understand and apply the guidance
- The recommended guidance involves regulations that are outmoded, ineffective, insufficient, or excessively burdensome and that should be modified, streamlined, expanded, or repealed
- The IRS can administer the recommended guidance on a uniform basis
- The recommended guidance reduces controversy and lessens the burden on taxpayers or the IRS
Submissions are due by May 16 for inclusion on the original PGP. Although recommendations can be submitted at any time, later recommendations may not be considered until future years.