IRS Seeks Input on 2019-2020 Priority Guidance Plan

The Treasury Department and the IRS welcome comments about what should be included in their 2019-2020 Priority Guidance Plan. The plan will identify guidance projects that the Treasury and the IRS intend to work on during the 12-month period from July 2019 to July 2020. They made the announcement in IRS Notice 2019-30, which was issued on April 25.

TCJA Important

The Treasury and the IRS expect to continue to prioritize guidance implementing the Tax Cuts and Jobs Act (TCJA), and the 2019-2020 plan will reflect that. They also say that “only a limited number” of projects not related to the TCJA will be added to their priorities for 2019-2020.

Carryovers

The Treasury and the IRS say that “a number” of guidance projects not related to the TCJA that had been listed in the 2018-2019 Priority Guidance Plan will not be completed by June 30, 2019. They may be carried over to the 2019-2020 Priority Guidance Plan; however, not all of them will be. The IRS attributes this to “resource limitations.”

Criteria

The Treasury and IRS say that in reviewing recommendations and selecting additional projects for inclusion on the 2019-2020 Priority Guidance Plan, they will consider the following:

1. Whether the recommended guidance resolves significant issues relevant to many taxpayers
2. Whether the recommended guidance reduces controversy and lessens the burden on taxpayers or the IRS
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 Whether the recommendation involves existing regulations or other guidance that is outdated, unnecessary, ineffective, insufficient or unnecessarily burdensome and that should be modified, streamlined, expanded, replaced or withdrawn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 would be in accordance with Executive Order 13771 (82 FR 9339), Executive Order 13777 (82 FR 12285), Executive Order 13789 (82 FR 19317), or other executive orders
5. Whether the recommended guidance promotes sound tax administration
6. Whether the IRS can administer the recommended guidance on a uniform basis
7. Whether the recommended guidance can be drafted in a manner that will enable taxpayers to easily understand and apply the guidance

Submitting Comments

Recommendations for possible inclusion in the 2019-2020 Priority Guidance Plan must be submitted by Friday, June 7, 2019.

There is no requirement concerning the format to be used for the recommendations. The Treasury and the IRS do say, however, that recommendations should include a brief description of why the guidance being requested is necessary. They add that “it would be helpful” if those making more than one suggestion would prioritize the projects by order of importance. Similarly, it would be helpful if those recommending a large number of projects grouped them by subject matter and concerning whether they are a high, medium or low priority, they say.

Comments may be submitted electronically via the federal eRulemaking Portal at www.regulations.gov (type IRS-2019-0019 in the search field on the regulations.gov homepage to find this notice and submit comments).

They also may be sent by mail to:
 
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2019-30) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044