The 2025-2026 Priority Guidance Plan (“Plan”), released on September 30, lists projects that the Department of the Treasury and the Internal Revenue Service plan to focus on.
The projects, after input from interested parties, are those that have been determined to be the most important to taxpayers and tax administration. The Plan lists priorities for the period beginning July 1, 2025, through June 30, 2026 and focuses on five main areas including:
- Implementation of the One Big Beautiful Bill Act;
- Deregulation and burden reduction;
- Guidance addressing Tribal tax issues;
- Digital assets; and
- The SECURE 2.0 Act.
New Projects Targeting Tax-Exempt Organizations
Among the new projects, one will focus on the statutory restriction in Internal Revenue Code Section 501(c)(3) that prohibits tax-exempt organizations from participating in or intervening in political campaigns—a rule commonly referred to as the Johnson Amendment. The second new initiative will examine how the fundamental public policy against racial discrimination, including recent legal developments, affects the eligibility of private schools to qualify for tax-exempt status under Internal Revenue Code Section 501(c)(3).
Additional Provisions Affecting Tax-Exempt Organizations
In addition to the new projects, a few of the provisions affecting tax-exempt organizations are listed below. A copy of the 2025-2026 Priority Guidance Plan can be accessed by clicking here.
- Final regulations under §4966 regarding donor advised funds, including excise taxes on sponsoring organizations and fund management. Proposed regulations were published on November 14, 2023.
- Guidance under §4960 regarding excess compensation paid by applicable tax-exempt organizations, including the expanded definition of “covered employee.”
- Regulations under §4945 regarding expenditure responsibility requirements.
- Guidance under §25F on the income tax credit for contributions of individuals to scholarship-granting organizations.
- Regulations under §4968 regarding excise tax based on investment income of certain private colleges and universities.
- Regulations under §6104 regarding the place for public inspection of materials relating to tax-exempt organizations, pensions and other plans.
- Guidance concerning the reporting of charitable contributions of trusts under §6034.
If you would like further information on any of these areas, please contact Schneider Downs for any questions.
About Schneider Downs Tax Services
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