Following recommendations from interested parties as to which tax issues should be addressed through revenue rulings, procedures, notices and other administrative guidance, the Internal Revenue Service released its 2024-25 Priority Guidance Plan on October 4. This year’s Plan contains 231 guidance projects.
While many of the projects carry over year-to-year, the 2024-25 Plan adds a new project illustrating the application of regulations under Section 501(r), which apply to hospital organizations described in Section 501(c)(3). The IRS’ commitment to guiding 501(r) aligns with the Tax-Exempt/Government Entity Group’s list of priorities and the agency’s overall strategic operating plan. (See our earlier article here.)
One exempt organization project was removed from the 2024-25 Plan related to final regulations for Section 509(a)(3) supporting organizations, which were published in October 2023.
The 2024-25 Priority Guidance Plan includes 10 projects under the “Exempt Organizations” heading:
- Guidance revising Rev. Proc. 80-27 regarding group exemption letters. Notice 2020-36 was published on May 18, 2020.
- Guidance illustrating the application of regulations under Section 501(r).
- Regulations under Section 512 regarding the allocation of expenses in computing unrelated business taxable income and addressing how changes made to Section 172 net operating losses by Section 2303(b) of the CARES Act apply for purposes of Section 512(a)(6).
- Guidance addressing the SECURE 2.0 Act changes relating to Section 529.
- Guidance under Section 4941 regarding a private foundation’s investment in a partnership in which disqualified persons are also partners.
- Final regulations under Section 4966 regarding donor-advised funds, including excise taxes on sponsoring organizations and fund management. Proposed regulations were published on November 14, 2023.
- Regulations under Section 4967 regarding prohibited benefits, including excise taxes on donors, donor advisors, related persons and fund management.
- Regulations under Section 4958 regarding donor-advised funds and supporting organizations.
- Guidance regarding the public-support computation with respect to distributions from donor-advised funds.
- Final regulations designating an appropriate high-level Treasury official under Section 7611. Proposed regulations were published on August 5, 2009.
Under the “General Tax Issues” heading, the IRS lists three projects of note for tax-exempt entities:
- Guidance under Section 170 regarding charitable contributions.
- Guidance under Section 170 regarding conservation easements, including façade easements.
- Guidance under Section 7701 providing criteria for treating an entity as an integral part of a state or local government, and guidance on federally and tribally chartered Tribal entities.
The IRS also has six projects this year under the heading “Tax-Exempt Bonds”:
- Guidance under Section 142, as amended by the Infrastructure Investment and Jobs Act.
- Revenue procedure providing guidance on the use of average area purchase prices and median income figures for purposes of Section 143.
- Regulations under Sections 148 and 150 on refunding bonds.
- Revenue procedure on the recovery of rebate under Section 148.
- Regulations under Section 149 to update requirements for certain tax-exempt bond information returns.
- Final regulations on bond reissuance under Section 150. Proposed regulations were published on December 31, 2018.
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