On Tuesday, September 29, 2026, the U.S. Department of the Treasury and the Internal Revenue Service released the 2026–2027 Priority Guidance Plan. The plan identifies 121 projects that will guide the agencies’ allocation of resources from October 1, 2026, through September 30, 2027. For tax exempt organizations, relevant guidance extends beyond the plan’s dedicated Tax-Exempt Organizations section. The guidance projects reflect the Treasury Department’s and the IRS’s focus on the following key areas: continued implementation of the One, Big, Beautiful Bill Act (OBBBA); deregulation and burden reduction; and guidance addressing tax exempt organizations, Tribal tax issues, digital assets, and other priorities.
One, Big, Beautiful Bill Act Implementation
The Priority Guidance Plan includes 40 projects related to implementation of the OBBBA. For exempt organizations, the most significant items in this section include regulations under Section 25F on the credit for contributions to scholarship-granting organizations, regulations under Section 4960 regarding excise tax rules on executive compensation, and regulations under Section 4968 affecting certain private colleges and universities regarding investment-income taxes.
Deregulation and Burden Reduction
This section contains 54 projects intended to remove, simplify, or update existing guidance. Exempt-organization items include regulations on private foundation expenditure responsibility, voluntary employees’ beneficiary associations (VEBAs), charitable contribution reporting by trusts, and public inspection of tax-exempt organization materials.
Tax Exempt Organizations
The Priority Guidance Plan includes five projects that are directly relevant to exempt organizations:
- Final regulations regarding the application of the fundamental public policy against racial discrimination in determining the eligibility of private schools for recognition of tax-exempt status under Section 501(c)(3). Proposed regulations were published on September 4, 2026.
- Guidance on the statutory prohibition in Section 501(c)(3) against participation or intervention in political campaigns (the “Johnson Amendment”).
- Guidance revising Rev. Proc. 2026-08 for certain types of group exemption letters.
- Guidance regarding certain donor advised fund arrangements.
- Guidance regarding exempt organization information reporting requirements, including with regard to fiscal sponsorship arrangements.
Other Priorities
The Priority Guidance Plan also includes projects involving health care tax issues, fringe benefits, refunding bonds, and SECURE 2.0 implementation.
The Schneider Downs Not-for-Profit industry group serves the organizations that serve our communities, with assurance, tax, advisory and technology solutions built for mission-driven work. We understand that not-for-profits answer to boards, donors, grantors and the public at once, and we help you meet every one of those obligations with confidence, including as new IRS and Treasury guidance changes the rules you operate under. To learn more, visit our Not-for-Profit Industry Group page, contact us, or email us directly. For exempt organization tax support, visit our Tax Services page.
