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IRS priority guidance plan 2019-2020 — exempt organization projects

IRS priority guidance plan 2019-2020

The U.S. Treasury Department and IRS on October 8, 2019, released the 2019-2020 priority guidance plan.


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The 2019-2020 priority guidance plan [PDF 97 KB] is a list of projects that Treasury and the IRS intend to work on during the 12-month period ending June 30, 2020, and includes guidance for implementing certain measures under the 2017 U.S. tax law that is often referred to as the “Tax Cuts and Jobs Act” (Pub. L. No. 115-97).

Projects affecting exempt organizations that have not appeared on past priority guidance plans include guidance on group exemption letters, on circumstances under which LLCs can qualify for section 501(c)(3) status, and on new electronic filing requirements for exempt organization returns. One project affecting exempt organizations that appeared in past priority guidance plans that was removed from the 2019-2020 plan is guidance under section 512 regarding methods of allocating expenses relating to dual use facilities—although this issue may potentially be addressed as part of the work on regulations under section 512(a)(6), another project on the plan.

The projects affecting exempt organizations, charitable giving, and tax-exempt bonds are listed below. 

Exempt organization guidance under the Tax Cuts and Jobs Act

  • Regulations on the excise tax on excess remuneration paid by “applicable tax-exempt organizations” under section 4960 (Notice 2019-09 released on December 31, 2018)
  • Final regulations on the excise tax on net investment income of certain private colleges and universities under section 4968 (proposed regulations published on July 3, 2019)
  • Regulations under section 274 concerning qualified transportation fringes, including the application of section 512(a)(7) (Notice 2018-99 released on December 10, 2018)
  • Regulations on computation of unrelated business taxable income for separate trades or businesses under section 512(a)(6) (Notice 2018-67 released on August 21, 2018)
  • Regulations under section 170 providing rules governing the availability of the charitable contribution deduction when a taxpayer receives or expects to receive a state or local tax credit (final regulations published on June 13, 2019)
  • Regulations on the increased contribution limit under section 529A (proposed regulations released on October 9, 2019), and final regulations under section 529A on qualified ABLE programs (proposed regulations published on June 22, 2015)

Other guidance projects concerning exempt organizations

  • Guidance revising Rev. Proc. 80-27 regarding group exemption letters
  • Guidance on circumstances under which an LLC can qualify for recognition under section 501(c)(3)
  • Guidance implementing section 3101 of the Taxpayer First Act on new electronic filing requirements for exempt organization returns
  • Final regulations on section 509(a)(3) supporting organizations (proposed regulations published on February 19, 2016)
  • Guidance under section 4941 regarding a private foundation’s investment in a partnership in which disqualified persons are also partners 
  • Guidance regarding the excise taxes on donor-advised funds and fund management (Notice 2017-73 released on December 4, 2017)
  • Regulations and other guidance under section 6033 relating to exempt organization filing requirements and the reporting of contributions (proposed regulations published on September 10, 2019)
  • Final regulations under section 6104(c) (proposed regulations 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 published on August 5, 2009)


Projects listed under the heading “Tax-exempt Bonds”  

  • Guidance on private activity bonds under section 141
  • Final regulations on bond reissuance under section 150 (proposed regulations published on December 31, 2018)
  • Guidance on corrective actions for tax-advantaged bonds
  • Guidance under sections 144(b) and 150 on qualified student loan bonds
  • Revenue procedure on the recovery of rebate under section 148
  • Guidance on direct payments for tax-advantaged bonds under section 6431
  • Guidance on tax-advantaged bond appeals procedures


Projects relating to charitable contributions

  • Guidance under section 170(e)(3) regarding charitable contributions of inventory


Other projects

  • 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
  • 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 published on February 6, 2014)
  • Final regulations on the fractions rule under section 514(c)(9)(E) (proposed regulations published on November 23, 2016)


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

Ruth Madrigal | +1 202 533 8817 |

Preston Quesenberry | +1 202 533 3985 |

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