In Notice 2022-21, the IRS invited the public Tuesday to recommend tax issues to be addressed in its Priority Guidance Plan for July 1, 2022, through June 30, 2023.
The Priority Guidance Plan is used by the IRS and Treasury's Office of Tax Policy to identify and rank tax issues that can be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance, focusing on issues that are most important to taxpayers and beneficial to tax administration.
The current Priority Guidance Plan covering July 1, 2021, through June 30, 2022, was initially released in September 2021 with 193 identified guidance projects, 13 of which had been completed by Aug. 31, 2021. It was updated in February 2022 to reflect 21 guidance projects that had been published or released through Dec. 31, 2021, and another 11 projects that were not on the initial plan.
Each year, the IRS solicits recommendations for the plan, acknowledging the importance in formulating guidance of relying upon the experience and knowledge of the taxpayers and practitioners who must apply the rules implementing the tax laws.
Members of the public recommending guidance projects to be included in the upcoming plan are asked to do so by June 3, 2022. No particular format is specified, but the IRS strongly encourages they do so electronically at www.regulations.gov. There, they can type "IRS-2022-0007" in the search field to find Notice 2022-21 and then click on the "comment" button. Submitters can then type a comment of up to 5,000 characters and attach files. Submitters may identify themselves as writing on behalf of themselves or on behalf another individual or organization, or they may remain anonymous.
Submitters are asked to briefly describe the suggested guidance and explain its need. They may include an analysis of how an issue should be resolved. If they recommend changing current regulations or other guidance, they should explain how the change or changes could reduce taxpayer burdens or costs or benefit tax administration. If they submit multiple recommendations, the IRS requests they group them by subject matter and order and designate them by level of priority.
While the recommended guidance is not restricted as to scope or type of issue, the IRS suggests that a suggestion is most likely to be considered to deserve priority if it:
- Resolves significant issues relevant to a broad class of taxpayers;
- Reduces controversy and lessens the burden on taxpayers or the IRS;
- Relates to recently enacted legislation;
- 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;
- Promotes sound tax administration;
- Can be administered by the IRS on a uniform basis; and
- Can be drafted so as to enable taxpayers to easily understand and apply it.
— To comment on this article or to suggest an idea for another article, contact Paul Bonner at Paul.Bonner@aicpa-cima.com.
