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Tax & AccountingJune 17, 2022

ABA Tax Section recommends key issues for Treasury and the IRS to address in the next 12 months

Every year the Department of the Treasury and the Internal Revenue Service invite the public to submit recommendations for items to be included in the 2022-2023 Priority Guidance Plan.  

The Treasury and the IRS use the Priority Guidance Plan to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. The 2022-2023 Priority Guidance Plan will identify guidance projects that the Treasury Department and the IRS intend to actively work on as priorities from July 01, 2022, through June 30, 2023.

The American Bar Association Section of Taxation’s (ABA) May meeting included discussing the significant issues faced by the tax community and compiling a list of projects the Treasury and the IRS should prioritize during the next 12 months.  

On June 03, the ABA sent a letter to IRS Commissioner Charles Rettig, offering recommendations that covered a wide range of subject areas and topics such as:

  • Updating regulations under Code Sec. 6662 to incorporate changes in the law
  • Issuing regulations or guidance addressing the application of the affiliation rules of Code Sec. 1504(a)
  • Important issues covering topics in corporate tax, cryptocurrency, capital recovery and leasing, exempt organizations, and several other areas

The letter assigns a letter of priority for each of the recommendations. 

The ABA’s letter and a complete list of topics and issues suggested for inclusion in the 2022-2023 Priority Guidance Plan can be found here.  

While the window to submit recommendations for possible inclusion on the 2022-2023 Priority Guidance Plan closed on June 03, 2022, Taxpayers may submit recommendations for guidance at any time throughout the year. Pages three and four of Notice 2022-21 detail the preferred format and structure of recommendations for guidance; while no particular format is required, recommendations are requested to have:

  • A brief description of the recommended guidance to include the need for such guidance
  • An analysis of how the issue should be resolved
  • An explanation of how changes would reduce taxpayer cost and/or burden/benefit tax administration (if making recommendations to modify, streamline, or withdraw existing regulations or other guidance)
  • Projects prioritized in order of importance (if more than one recommendation is suggested)

Recommendations for guidance can be submitted electronically via the Federal eRulemaking Portal, or sent by mail to:  

Internal Revenue Service  
Attn: CC:PA:LPD:PR (Notice 2022-21) Room 5203 
P.O. Box 7604  
Ben Franklin Station Washington, D.C. 20044

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Mark Friedlich
Vice President of US Affairs for Wolters Kluwer Tax & Accounting
Mark Friedlich, a CPA & tax lawyer, is the Vice President of US Affairs for Wolters Kluwer Tax & Accounting. He is a member of the U.S. Senate Finance Committee’s Chief Tax Counsel’s Advisory Board, advisor to 14 state taxing authorities, and has been a member of the American Bar Association’s Tax Section and AICPA’s Tax Section leadership teams. Prior to joining Wolters Kluwer he was a COO and Principal at PwC.


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