IRS lists fiscal sponsorship and DAF rules as priorities

The Treasury Department and the IRS have published their 2026–2027 Priority Guidance Plan, dated September 29. It lists 121 projects the agencies will focus on during the plan year, which for the first time matches the federal fiscal year and runs from October 1, 2026, to September 30, 2027. The plan sets priorities, not deadlines.

Five projects for exempt organizations

1. Private schools. Final regulations on how the public policy against racial discrimination, "including consideration of recent caselaw," applies to private schools seeking 501(c)(3) status. The proposed rules were published on September 4, as we noted in our story on exemption appeals.
2. The Johnson Amendment. Guidance on the ban on 501(c)(3) participation or intervention in political campaigns. The same item was on last year's plan.
3. Group exemptions. Guidance revising Rev. Proc. 2026-08 for certain types of group exemption letters.
4. Donor-advised funds. Guidance under sections 4966 and 6033 on "certain donor advised fund arrangements." Last year's plan instead called for final regulations on the donor-advised fund rules proposed in November 2023. That item is not on this year's plan.
5. Fiscal sponsorship. Guidance on information reporting by exempt organizations, "including with regard to fiscal sponsorship arrangements." In April, Treasury said the IRS planned to revise Form 990 to get clearer reporting on sponsorships, as we reported in our fiscal sponsorship story.

Elsewhere in the plan

Among the items implementing the One, Big, Beautiful Bill Act are regulations for the federal scholarship tax credit, which the IRS proposed on October 1, and for the excise tax on the investment income of certain private colleges and universities. The list also includes regulations on the tax on excess compensation paid by tax-exempt organizations, including the expanded definition of "covered employee."

Other projects cover the expenditure responsibility rules private foundations follow for some grants, final rules on how trusts report charitable contributions, and where the public can inspect exempt organizations' filings. Treasury and the IRS say they will update the plan during the year, expect to add deregulatory items, and take comments throughout.