Treasury Priority Guidance Plan 2021-2022 – Exempt Organizations

Jun 16, 2021
Jun 16, 2021
0 min. read

The Treasury Department and IRS recently released the 2021-2022 Priority Guidance Plan, containing guidance priorities for the 12-month period from July 1, 2021 through June 30, 2022.

The 2021-2022 Priority Guidance Plan contains 193 items, but does not contain any deadline for completing the projects. Projects listed on the 2021-2022 plan affecting exempt organizations are as follows:

  • Guidance revising Rev. Proc. 80-27 regarding group exemption letters. (Notice 2020-36 was published on May 18, 2020.)
  • Guidance on circumstances under which an LLC can qualify for recognition under section 501(c)(3).
  • Final regulations on section 509(a)(3) supporting organizations. (Proposed regulations were published on Feb. 19, 2016.)
  • Regulations under section 512 regarding the allocation of expenses in computing unrelated business taxable income and addressing how changes made to section 172 net operating losses by section 2303(b) of the CARES Act apply for purposes of section 512(a)(6).
  • 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.
  • Regulations under section 6104(c) related to disclosure of certain information to state officials. (Proposed regulations were published on March 15, 2011.)
  • Regulations designating an appropriate high-level Treasury official under section 7611 related to church audits. (Proposed regulations were published on Aug. 5, 2009.)

RSM insights

Each of the exempt organization projects also appeared on the 2020-2021 Priority Guidance Plan, with a slight modification regarding the guidance related to section 512(a)(6). In addition, the plan no longer includes a project for additional guidance under section 170(e)(3) regarding charitable contributions of inventory.

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