IRS priority guidance plan 2017-2018 - KPMG United States
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IRS priority guidance plan 2017-2018—exempt organization projects

IRS priority guidance plan 2017-2018

The IRS today released the 2017-2018 priority guidance plan—often referred to as the IRS “business plan”—that sets forth guidance priorities for the IRS and Treasury Department for the period July 1, 2017, through June 30, 2018.


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The exempt organization guidance projects included in the 2017-2018 priority guidance plan [PDF 302 KB] are summarized below.

Projects under the heading “Exempt Organizations”

  • Update revenue procedures on grantor and contributor reliance under sections 170 and 509, including an update to Rev. Proc. 2011-33 for EO Select Check 
  • Final regulations on section 509(a)(3) supporting organizations (proposed regulations were published on February 19, 2016) 
  • Guidance under section 512 regarding methods of allocating expenses relating to dual-use facilities
  • Guidance on section 529(c)(3)(D) on the recontribution within 60 days of refunded qualified higher education expenses 
  • Final regulations under section 529A on “qualified ABLE programs” (proposed regulations were published on June 22, 2015)
  • Guidance under section 4941 regarding a private foundation's investment in a partnership in which disqualified persons are also partners  
  • Update to Rev. Proc. 92-94 on sections 4942 and 4945 (published October 2, 2017 as Rev. Proc. 2017-53)
  • Guidance regarding the excise taxes on donor advised funds and fund management
  • Final regulations under section 6104(c) (proposed regulations were published on March 15, 2011)
  • Final regulations designating an appropriate high-level Treasury official under section 7611 relating to church tax inquiries and examinations (proposed regulations were published on August 5, 2009)

Guidance projects listed under the heading “Tax-exempt Bonds”

  • Guidance on remedial actions for tax-advantaged bonds under sections 54A, 54AA, and 141
  • Guidance on private activity bonds under section 141
  • Regulations on public approval requirements for private activity bonds under section 147(f) (proposed regulations were published September 28, 2017)
  • Guidance on rebate overpayment under section 148 (published September 11, 2017 as Rev. Proc. 2017-50)
  • Regulations on bond reissuance under section 150

Projects relating to charitable contributions

  • Final regulations under section 170 regarding charitable contributions (proposed regulations were published August 7, 2008)
  • Guidance under section 170(e)(3) regarding charitable contributions of inventory

Other projects

Other projects of interest to exempt organizations include:

  • Projects involving employee benefits
  • Guidance under section 7701 providing criteria for treating an entity as an integral part of a state, local, or tribal government
  • Guidance under section 6050S relating to Form 1098-T, Tuition Statement (proposed regulations were published on August 2, 2016) 
  •  Revenue ruling under section 102 regarding whether contributions of money received through a crowdfunding site to pay for medical expenses under section 213 are excludable from income because the contributions are gifts
  • Final regulations under section 512 explaining how to compute unrelated business taxable income of voluntary employees’ beneficiary associations described in section 501(c)(9) (proposed regulations were published on February 6, 2014)
  • Final regulations on the fractions rule under section 514(c)(9)(E) (proposed regulations were published on November 23, 2016)

Notable changes

  • Update to Rev. Rul. 67-390, which requires tax-exempt organizations that undergo legal structural changes to reapply for tax-exempt status (identified as a “Near-Term Burden Reduction” project, which the Treasury and IRS have identified as burden reducing and that they believe can be completed in the 8½ months remaining in the plan year)
  • Proposed regulations under section 501(c) relating to political campaign intervention (removed) 
  • Guidance under section 6033 relating to the reporting of contributions (removed) 
  • Guidance under section 170 regarding charitable contributions of appropriative water rights (removed)
  • Guidance under section 170 regarding charitable contributions of conservation easements (removed)


For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Preston Quesenberry | +1 202 533 3985 | 

Randall Thomas | +1 202 533 3786 |

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