Blog · 15 October 2026

IRS Priority Guidance Plan 2026–2027: 121 Projects, a New Fiscal-Year Calendar and What US CPA Firms Should Watch

By Keshav Bansal, CA

On September 29, 2026, the Treasury Department and the IRS released the initial IRS Priority Guidance Plan 2026–2027. It lists 121 guidance projects that Treasury’s Office of Tax Policy and the IRS intend to focus on between October 1, 2026 and September 30, 2027. For US CPA firms, the Priority Guidance Plan is the closest thing to a public roadmap of which regulations, revenue rulings, revenue procedures and notices may arrive next, especially for the One, Big, Beautiful Bill Act (OBBBA). It is also easy to misread. Below is what the plan is, what changed this year, and which items deserve a place on your firm’s watch list.

What the Priority Guidance Plan is (and is not)

The IRS describes the plan as the way Treasury and the IRS “identify and prioritize” tax issues that should be addressed through published administrative guidance. The joint statement that opens the 2026–2027 plan, signed by Kevin M. Salinger (Acting Assistant Secretary for Tax Policy and Acting IRS Chief Counsel) and Frank J. Bisignano (IRS Chief Executive Officer), makes three points worth repeating to clients:

• It is a resource-allocation list. The projects are “priorities for allocating Treasury Department and IRS resources” during the plan year.
• It has no deadlines. In the statement’s words, “the plan does not provide any deadline for completing the projects.”
• It will change. Treasury and the IRS intend to update the plan during the year for new priorities, published guidance and legislative developments, and expect to add more deregulatory items.

A listed project is not law and not a proposal. The Internal Revenue Code, and regulations and other guidance once actually issued, are what bind taxpayers. The plan tells you where the IRS is spending its effort, not what the answer will be.

What is new in the 2026–2027 plan

Two changes stand out against last year’s plan:

• The plan year now follows the federal fiscal year. The 2025–2026 plan covered July 1, 2025 through June 30, 2026. Beginning with this plan, the 12-month plan year runs October 1 to September 30.
• More projects. The initial 2025–2026 plan contained 105 projects; the initial 2026–2027 plan contains 121.

The 121 projects fall into six groups: OBBBA implementation (40), deregulation and burden reduction (54), tax-exempt organizations (5), Tribal tax issues (1), digital assets (4) and other priorities (17). The plan says recommendations were requested from the public in Notice 2026-23, and an appendix lists routine guidance published every year.

OBBBA items to watch for individual and small-business clients

Many OBBBA projects concern energy credits, international rules and large corporations. Those most likely to affect a typical CPA firm’s 1040, 1120-S and 1065 work include:

• Regulations under §199A on the qualified business income deduction (item 20). See our QBI deduction §199A 2026 guide for the current rules.
• Final regulations under §§6041 and 6041A on the increased information-reporting threshold for certain payees (item 38). The plan notes proposed regulations were published on April 17, 2026. Our post on the Form 1099-NEC $2,000 threshold covers what changes for payers.
• Regulations under §1202 on the qualified small business stock exclusion (item 32).
• Regulations under §2010 on the extended and enhanced estate and gift tax exemption (item 34).
• Guidance under §274(o) on meals provided for the convenience of the employer (item 23).
• Regulations under §168(k) on bonus depreciation (item 17) and §§174 and 174A on research and experimental expenditures (item 19).
• Trump accounts under §§128, 139J, 530A, 6434 and 6659 (item 12), the §25F scholarship credit (item 1), and §529 and §530 education guidance (items 25 and 26).
• Final regulations under §1062 on farmland sales (item 31); proposed regulations were published September 29, 2026.
• Guidance under §165(h)(5) on State declared disasters (item 16).

Procedure and burden-reduction items that change daily practice

The deregulation group is the largest, and several items touch firm workflows rather than tax rates:

• A revenue procedure updating Rev. Proc. 2015-13, the procedures for automatic and non-automatic accounting method changes.
• A revenue procedure updating Rev. Proc. 2012-17 to allow certain electronic furnishing of schedules required under §6031, the partnership return provision.
• A revenue procedure under §1362(f) on the validity or continuation of an S corporation or QSub election.
• Guidance on EIN assignment under §6109 in F reorganizations involving S corporations.
• Regulations under the centralized partnership audit regime of the Bipartisan Budget Act of 2015.
• An announcement updating transition-period and electronic submission rules for Forms W-9.
• Regulations to remove regulations under §7508A regarding the mandatory 60-day postponement for federally declared disasters. Our §7508A disaster relief guide explains how postponements work today.

A quiet item on penalty protection: Fact Sheet FAQs

Under “other priorities,” the plan lists regulations modifying Treas. Reg. §1.6662-4(d)(3)(iii) “to add Fact Sheet FAQs to the list of substantial authority.” Today that regulation lists what counts as authority for the substantial understatement penalty, including the Code, regulations, revenue rulings and procedures, court cases, IRS information or press releases, and notices and announcements published in the Internal Revenue Bulletin. FAQs that appear only on IRS.gov are not on the list. Until a final regulation says otherwise, keep treating FAQs as helpful but not as substantial authority, and document the underlying authorities in your workpapers.

The appendix: routine guidance you can plan around

The appendix lists regularly scheduled publications by month. For tax-season planning, the useful ones are:

• October 2026: the revenue procedure on inflation-adjusted items for 2027.
• November 2026: the notice of cost-of-living adjustments, effective January 1, 2027, to retirement-plan dollar limits.
• December 2026: the notice of 2027 optional standard mileage rates.
• Each quarter: the §6621 revenue ruling on overpayment and underpayment interest rates, plus monthly applicable federal rate tables.

These are scheduled months, not guaranteed release dates.

How US CPA firms can use the plan

1. Build a watch list by client segment. Map the items above to the clients they affect: pass-throughs for §199A and §1062, family businesses and estate clients for §2010, payers for the §6041 threshold, startups for §1202.
2. Do not wait for guidance that may not come. With no deadlines, file on the statute and existing guidance. Where proposed regulations exist, note whether taxpayers may rely on them before finalization.
3. Set client expectations. When a client hears “the IRS is working on it,” explain that a plan listing is a priority, not a promise or a rule.
4. Check updates. The IRS posts plan versions on its Priority Guidance Plan page. Re-check after each update for added deregulatory items or newly published guidance.
5. Comment when it matters. Treasury and the IRS invite comments throughout the plan year. Practical comments from practitioners help.

Where Tax Brew fits

New guidance usually lands mid-season, when review time is shortest. Tax Brew supports US CPA firms with tax prep support, bookkeeping and cleanup so your reviewers can spend more of their time on judgment calls like these. See our services, or email info@taxbrewglobal.com.

Sources: Department of the Treasury, 2026–2027 Priority Guidance Plan (initial version, September 29, 2026) and 2025–2026 Priority Guidance Plan (initial version); IRS Priority Guidance Plan page; Treas. Reg. §1.6662-4(d)(3)(iii). This article is general information, not tax advice for any specific client.