With a potential government shutdown clouding the immediate horizon, tax legislation may be on the back burner in Congress, but attention has turned to the pending release of the Priority Guidance Plan (PGP) by the Department of the Treasury and the Internal Revenue Service (IRS).

Each year, Treasury's Office of Tax Policy and the IRS publish the PGP to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. The PGP lists those guidance projects that are priorities during the July 1 through June 30 plan year. Although the 2025-2026 PGP plan year began on July 1, 2025, it's not uncommon for the PGP to be issued well after the start of the plan year.

Kevin Salinger, Deputy Assistant Secretary for Tax Policy, noted that although the release of the PGP is scheduled for later this month or in early October, guidance has already been issued with respect to the One Big Beautiful Bill Act (OBBBA) regarding the treatment of research and experimental expenditures, green energy credits, and the new "no tax on tips" provision.

Deputy Assistant Secretary Salinger suggests that there may be a complete revamping of the PGP in which Treasury and the IRS start with a clean slate – removing legacy guidance projects that have been on the PGP for years and focusing on guidance projects that are expected to come out during the plan year. Thus, the new PGP could focus on OBBBA implementation, deregulatory priorities (including additional guidance on the corporate alternative minimum tax (CAMT)), and taxation of digital assets. Within OBBBA implementation, the emphasis would be on provisions that go into effect this year (particularly in the international space), as well as Trump campaign tax relief provisions, such as no tax on tips and overtime, as well as deductions for seniors and domestic car loan interest.

Keep in mind that if a prolonged shutdown happens, it could impact not only the release of the PGP but also the subsequent release of its underlying guidance projects. #TaxTake 

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Mike discussed his extraordinary career and reflected on leadership, service, and the evolving landscape of federal tax practice in an interview for the Legends of the Tax Bar series.

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