In depth
Few projects listed
In contrast to previous years, when the PGP had grown quite voluminous, the 2025-2026 PGP is significantly slimmed down and lists only 105 projects (not including the list of regularly scheduled publications that appear in the appendix, such as the revenue rulings setting forth applicable federal rates for various purposes). This is fewer than half of the number of projects included on prior years’ PGPs — in previous years, the PGP appeared to be more of an “aspirational” list of guidance projects that Treasury and IRS wanted to reassure taxpayers were still on their radar, rather than a list of guidance projects that Treasury and IRS could realistically expect to publish over the course of the coming year. The new format appears more pragmatic, and it is reasonable for taxpayers to expect that Treasury and the IRS will publish most, if not all, of the projects identified on the 2025-2026 PGP by June 30, 2026.
Observation: The fact that a guidance project is not listed on the 2025-2026 PGP does not necessarily indicate that Treasury and IRS staff are not working on such a guidance project at all but rather that Treasury and IRS do not expect to publish additional guidance on that topic by June 30, 2026.
Substantial reorganization
The format of the 2025-2026 PGP has also been substantially reorganized from prior years, where projects were grouped by technical topics (such as Consolidated Returns, Corporations and Their Shareholders, Financial Institutions and Products). This year’s PGP is organized into categories such as the scope of each category is easier for non-tax professionals to understand. The PGP has identified the following categories for guidance:
- One, Big, Beautiful Bill Act (OBBBA) implementation
- Deregulation and burden reduction
- Section 501(c)(3) issues
- Tribal tax issues
- Digital assets
- SECURE 2.0 Act and other guidance
While taxpayers’ specific circumstances will dictate which guidance projects are of the greatest interest to them, it should not be surprising that, as a general matter, the categories for OBBBA implementation and deregulation and burden reduction have garnered the most attention since the PGP was published.
OBBBA implementation
The 40 guidance projects listed in this category are practically a CliffsNotes version of the OBBBA’s highest-profile provisions. Some of these provisions are effective in 2025 — such as the “no tax on tips” and “no tax on overtime” provisions — which likely explains why Treasury and IRS have continued to make progress on these guidance projects even during the shutdown of the federal government (such as by holding a hearing on the proposed regulations for “no tax on tips” and issuing Notice 2025-62, granting penalty relief for information reporting for the new tips and overtime provisions for the 2025 calendar year). Similarly, section 898(c)(2) is repealed for taxable years of specified foreign corporations beginning after November 30, 2025, suggesting that we are likely to see at least preliminary guidance on this change by late November.
If Treasury’s actions to issue guidance under the Tax Cuts and Jobs Act during President Trump’s first term are any indication, taxpayers can likely expect Treasury and IRS to work to issue OBBBA guidance as expeditiously as possible.
Deregulation and burden reduction
Given President Trump’s interest in deregulatory actions and reducing burdens across the administration, it should come as no surprise that the 46 guidance projects listed in this category appear second on the PGP. The projects listed here are a combination of recommendations for deregulatory projects from taxpayers and other outside stakeholders, as well as the result of Treasury and IRS’s own internal review of existing guidance projects.
For example, many commenters had requested withdrawal or other changes to the funding rule in section 4501’s excise tax on stock buybacks and were likely pleased to see that final regulations under section 4501 are included on the deregulation and burden reduction list.
Observation: There are two “catch-all” items that appear on this list: (1) “[a]dditional notices removing unnecessary Internal Revenue Bulletin guidance” and (2) “[r]egulations eliminating unnecessary tax regulations,” so taxpayers should not assume that, if a project isn’t explicitly listed on the deregulation and burden reduction list, it is automatically off the table.
Conclusion
While time will tell whether this streamlined approach to drafting the PGP is a more accurate representation of the projects that Treasury and IRS anticipate publishing by the June 30 PGP-yearend, it does helpfully emphasize Treasury’s top guidance priorities. Taxpayers would be well advised to review the items listed on the 2025-2026 PGP and prioritize their government engagement on the items listed there.
