IRS 2026–2027 Priority Guidance Plan: What Practitioners Should Watch

Veltriqa LLC · Tax newsletter / practitioner brief

Audience: Business owners, tax practitioners, exempt organizations, and compliance professionals · veltriqa.com

Date: September 30, 2026

Why this matters now

On September 29, 2026, the Department of the Treasury and the IRS (Internal Revenue Service) released the initial 2026–2027 Priority Guidance Plan (PGP). The plan lists the guidance projects that will be the focus of Treasury and IRS resources during the plan year beginning October 1, 2026, and ending September 30, 2027.

Beginning with this cycle, the 12-month “plan year” aligns with the federal government’s fiscal year. The document states that the plan does not provide any deadline for completing the projects.

The initial plan contains 121 guidance projects. The joint statement highlights three themes that run through the list: continued implementation of the One, Big, Beautiful Bill Act (OBBBA); deregulation and burden reduction; and guidance on tax-exempt organizations, Tribal tax issues, digital assets, and other priorities.

Public recommendations were solicited in Notice 2026-23. Treasury and the IRS say they intend to update the plan during the year as priorities shift, guidance is published, and legislation develops.

For practitioners, the PGP is a roadmap — not a promise of timing. It tells you where legal guidance is coming, so you can flag clients whose facts sit on that list.

How the plan is organized

The body of the plan is organized under six section headings (project counts below are the numbered items in each section of the September 29, 2026 release):

One, Big, Beautiful Bill Act (OBBBA) implementation — 40 projects

Deregulation and burden reduction — 54 projects

Tax exempt organizations — 5 projects

Tribal tax issues — 1 project

Digital assets — 4 projects

Other priorities — 17 projects

An Appendix lists regularly scheduled publications (for example, inflation adjustments and applicable federal rate tables) that are generally published each plan year. Those routine items sit outside the 121-project count.

OBBBA implementation

Forty projects sit under One, Big, Beautiful Bill Act (OBBBA) implementation. Several will matter immediately for 2026 filing and planning conversations:

Cost recovery and research. Regulations under §168(k) on the special depreciation allowance for qualified property; regulations under §168(n) on qualified production property; and regulations and other guidance under §§174, 174A, and related provisions on research and experimental expenditures.

Business interest and QBI (qualified business income). Regulations under §163(j) on the limitation on deduction for business interest, and regulations under §199A on the deduction for qualified business income.

Compensation and meals. Regulations under §162(m) on excessive employee remuneration, and guidance under §274(o) on meals provided at the convenience of the employer.

International packages. Final regulations under §250 on foreign-derived deduction eligible income and net CFC (controlled foreign corporation) tested income; related expense allocation rules; and further subpart F / §951A work, including modifications tied to §§951B and 958(b)(4).

Savings and education. Guidance under §§128, 139J, 530A, 6434, and 6659 regarding Trump accounts (proposed regulations were published earlier in 2026); plus guidance under §529 and §530 on education-related enhancements.

Capital and wealth. Regulations under §1202 on QSBS (qualified small business stock); opportunity zone guidance under §§1400Z–1, 1400Z–2, and related reporting provisions; and regulations under §2010 on the extension and enhancement of increased estate and gift tax exemption amounts.

Credits and energy. A cluster of credit projects, including §45F employer-provided child care, §45Q carbon oxide sequestration, §45S paid family and medical leave, §45U zero-emission nuclear power, §45X advanced manufacturing, final §45Z clean fuel production rules, and domestic content bonus amounts under §§45Y and 48E.

Reporting thresholds. Final regulations under §§6041 and 6041A on the increase in the threshold for requiring information reporting with respect to certain payees (proposed regulations were published April 17, 2026).

Exempt-adjacent OBBBA items. Regulations under §4960 on excess compensation paid by applicable tax-exempt organizations (including an expanded “covered employee” definition), and regulations under §4968 on the excise tax based on investment income of certain private colleges and universities.

Deregulation and burden reduction

This is the largest section by count — 54 projects. The opening items are explicit: additional notices removing unnecessary Internal Revenue Bulletin guidance, and regulations eliminating unnecessary tax regulations.

Other practitioner-facing examples include:

Guidance under §41 on the credit for increasing research activities.

Regulations under §§55, 56A, and 59 regarding the CAMT (Corporate Alternative Minimum Tax).

A revenue procedure under §446 updating Rev. Proc. 2015-13 on accounting method changes.

Subchapter S regulations to conform with statutory changes, and a revenue procedure under §1362(f) on the validity or continuation of an S corporation or QSub (qualified subchapter S subsidiary) election.

Final regulations removing §1.6011-18 on partnership related-party basis adjustment transactions as transactions of interest.

A revenue procedure updating Rev. Proc. 2012-17 to allow certain electronic furnishing of schedules required under §6031.

Regulations under the centralized partnership audit regime established by the Bipartisan Budget Act of 2015.

Final regulations under §6311 (as amended by the Taxpayer First Act) on payment of taxes by debit and credit cards.

If a client’s pain point is method changes, S corporation elections, partnership reporting, or CAMT, this section is where to watch.

Tax-exempt organizations

Five projects:

1. Final regulations on the fundamental public policy against racial discrimination in determining private-school eligibility for §501(c)(3) recognition (proposed regulations published September 4, 2026).

2. Guidance on the statutory prohibition in §501(c)(3) against participation or intervention in political campaigns (the “Johnson Amendment”).

3. Guidance revising Rev. Proc. 2026-08 for certain types of group exemption letters.

4. Guidance under §§4966 and 6033 regarding certain donor advised fund arrangements.

5. Guidance under §6033 on exempt organization information reporting requirements, including fiscal sponsorship arrangements.

Tribal tax issues

One project: regulations under §139E regarding the requirements for Tribal general welfare benefits administered by Alaska Native Corporations.

Digital assets

Four projects cover the tax treatment of digital-asset transactions (including wrapping), electronic furnishing of information returns and payee statements under §6045, information reporting as amended by the Infrastructure Investment and Jobs Act, and U.S. broker reporting of digital-asset transactions of certain foreign persons in connection with the OECD (Organisation for Economic Co-operation and Development) Crypto-Asset Reporting Framework.

Other priorities

Seventeen projects round out the plan. Notable entries for many practices include IRS (Internal Revenue Service) Employee Plans program guidance updating the EPCRS (Employee Plans Compliance Resolution System) and adding a new ICRS (IRA Compliance Resolution System) to reflect SECURE 2.0 Act provisions; broader SECURE 2.0 implementation (including savers match, qualified student loan matching contributions, long-term part-time employees, pension-linked emergency savings accounts, and rollover rules); guidance under §132 on fringe benefits; transfer-pricing guidance under §482; REIT (real estate investment trust) income qualification tests under §856; and final regulations under §6011 identifying certain basket transactions as listed transactions.

What it means for planning this year

Treat the Priority Guidance Plan (PGP) as a watch list, not a calendar.

1. Match clients to projects. Bonus depreciation, qualified production property, research expenditures, §163(j), §199A, QSBS (qualified small business stock), opportunity zones, estate and gift exemption, Form 1099 thresholds, digital-asset reporting, and SECURE 2.0 are all on the list.

2. Expect updates. The joint statement says Treasury and the IRS (Internal Revenue Service) will refresh the plan during the year and expect to add more deregulatory items as comments are evaluated.

3. Do not invent timing. The plan expressly does not set completion deadlines. Build advice around current law and published proposed or temporary rules, then revisit when final guidance drops.

4. Use Notice 2026-23 and public comment channels. The agencies emphasize taxpayer engagement consistent with the Taxpayer First Act.

Additional copies of the plan are available from the IRS website at the Priority Guidance Plan page referenced in the release.

2026 depreciation rules practitioners need at hand

Cost recovery sits near the top of the Priority Guidance Plan (PGP) OBBBA (One, Big, Beautiful Bill Act) list. Until final regulations drop, keep these 2026 working numbers close. Figures below are transcribed from the Wolters Kluwer depreciation key facts sheet, revised January 20, 2026, provided via ADP.

Sec. 179 expensing (2026)

Dollar limitation: $2,560,000

Investment limitation: $4,090,000

2025 note: Dollar limitation $2,500,000; investment limitation $4,000,000. The dollar and investment limitations were retroactively increased by P.L. (Public Law) 119-21 for tax years beginning after 2024.

Sec. 179 heavy vehicle expensing limit (2026)

Dollar limitation: $32,000

Applies to: Heavy vehicles — SUVs (sport utility vehicles), trucks with bed-length under 6 feet, and vans with a seating capacity of less than 10 persons behind the driver’s seat — that are exempt from the Code Sec. 280F luxury vehicle caps.

Sec. 280F luxury vehicle limits

2026 row: Not shown on the source sheet.

Latest year shown — 2025:

1st year: $20,200 (higher limit if bonus depreciation claimed) / $12,200

2nd year: $19,600

3rd year: $11,800

4th year and later: $7,060

Vehicle note: Vehicle includes passenger cars, trucks, vans, and SUVs (sport utility vehicles). If a truck, van, or SUV exceeds 6,000 pounds GVWR (gross vehicle weight rating), it is not subject to the limits.

Bonus note: The higher first-year limit applies if bonus depreciation is claimed.

Standard mileage rates (2026)

Rates in cents per mile.

Business: 72.5

Medical / moving: 20.5

Charitable: 14

Basis adjustment: 35

Moving footnote: The moving expense deduction is repealed for tax years beginning after 2017, except for members of the U.S. Armed Forces.

Bonus depreciation rates (by placed-in-service window)

1/20/2025 and beyond: 100%

1/1/2025 – 1/19/2025: 40%

2024: 60%

2023: 80%

9/28/2017 – 2022: 100%

Qualified-property asterisk: Qualified property acquired before 1/20/2025 is subject to a 40% bonus rate if placed in service in 2025, a 20% bonus rate if placed in service in 2026, and a 0% rate thereafter.

Special bonus depreciation rates

Qualified production property: 100%. Applies to property constructed from 1/20/2025 – 12/31/2028 and placed in service before 2031.

Qualified re-use and recycling property: 50%. Applies to property placed in service after 8/31/2008.

Common recovery periods (GDS / ADS)

GDS (General Depreciation System) and ADS (Alternative Depreciation System) lives in years for assets practitioners ask about most:

Automobiles, taxis, light general-purpose trucks: GDS 5 / ADS 5

Computers and peripheral equipment: GDS 5 / ADS 5

Office furniture, fixtures, safes, communications equipment: GDS 7 / ADS 10

Land improvements (shrubbery, fences, roads, bridges not elsewhere classified): GDS 15 / ADS 20

Residential rental property (placed in service after 2017): GDS 27.5 / ADS 30

Nonresidential real property (placed in service after May 12, 1993): GDS 39 / ADS 40

Declining balance rates

Property classes and the year of switch to the SL (straight-line) method (used if optional table percentages are not used):

3-year: 200% DB (declining balance) 66.67% — switch year 3; 150% DB 50.00% — switch year 2

5-year: 200% DB 40.00% — switch year 5; 150% DB 30.00% — switch year 4

7-year: 200% DB 28.57% — switch year 6; 150% DB 21.43% — switch year 4

10-year: 200% DB 20.00% — switch year 7; 150% DB 15.00% — switch year 5

15-year: 150% DB 10.00% — switch year 7

20-year: 150% DB 7.50% — switch year 9

Optional MACRS percentage tables

The source sheet also prints optional MACRS (Modified Accelerated Cost Recovery System) half-year and mid-quarter percentage tables, plus month-by-month recovery percentages for 39-year, 31.5-year, and 27.5-year real property. Those grids are not repeated here.

Depreciation recapture (short rules)

Sec. 1245 property: 100%

MACRS (Modified Accelerated Cost Recovery System) residential and nonresidential real property: None

Bonus depreciation claimed on Sec. 1250 property: Bonus in excess of SL (straight-line) depreciation

Sec. 179 expense claimed on qualified real property: 100%

ACRS (Accelerated Cost Recovery System) 15-, 18-, and 19-year nonresidential real property depreciated using an accelerated method (treated as Sec. 1245 property): 100%

Other ACRS 15-, 18-, and 19-year real property (now fully depreciated Sec. 1250 property): None

Gain note: Ordinary income recapture applies to the extent of gain. Sec. 179 allowance and bonus depreciation are treated as depreciation subject to recapture.

Unrecaptured Sec. 1250: Unrecaptured depreciation on Sec. 1250 property owned by individuals, estates, or trusts is subject to a 25% tax rate.

Disclaimer

This article is general information for educational purposes. It is not tax, legal, accounting, or other professional advice. Do not rely on it as a substitute for advice from a qualified professional who understands your specific facts. Rules change, and project lists are not guarantees of timing or outcome.

Sources: Department of the Treasury / Internal Revenue Service, 2026–2027 Priority Guidance Plan (initial), joint statement dated September 29, 2026. Depreciation figures: Wolters Kluwer depreciation key facts, revised January 20, 2026, provided via ADP.