IRS Priority Guidance Plan 2020-2021—exempt organization projects

IRS Priority Guidance Plan 2020-2021

The U.S. Treasury Department and IRS have released the 2020-2021 Priority Guidance Plan.


Related content

The 2020-2021 Priority Guidance Plan [PDF 169 KB] is a list of projects that Treasury and the IRS intend to work on during the 12-month period ending June 30, 2021, 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).

Most of the listed projects affecting exempt organizations have appeared on past priority guidance plans.

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

Exempt organization-related guidance under the Tax Cuts and Jobs Act

  • Final regulations on the excise tax on excess remuneration paid by “applicable tax-exempt organizations” under section 4960 (proposed regulations published on June 11, 2020)
  • Regulations on computation of unrelated business taxable income for separate trades or businesses under section 512(a)(6) and allocation of certain expenses by exempt organizations with more than one unrelated trade or business (proposed regulations published on April 24, 2020)

Other guidance projects concerning exempt organizations

  • Guidance revising Rev. Proc. 80-27 regarding group exemption letters (Notice 2020-36 released May 18, 2020)
  • Guidance on circumstances under which a limited liability company (LLC) can qualify for recognition under section 501(c)(3)
  • Guidance updating electronic filing requirements for exempt organizations and employee plans to reflect changes made by the Taxpayer First Act
  • Revenue procedure modifying Rev. Proc. 2020-5, allowing for the new electronic submission process for Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, providing a 90-day transition relief period, and modifying procedures related to the submission of written requests of Canadian charities (Notice 2020-8 released February 18, 2020)
  • 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 
  • Regulations regarding the excise taxes on donor advised funds and fund management (Notice 2017-73 released December 18, 2017)
  • 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”  

  • Revenue procedure under section 143 providing guidance for use of the national and area median gross income figures
  • Guidance under sections 144(b) and 150 on qualified student loan bonds
  • Revenue procedure modifying the time period for the temporary relief provided in Rev. Proc. 2020-21 for public hearings under section 147
  • Revenue procedure on the recovery of rebate under section 148
  • 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 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 |

© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal