Articles 4 min read

Preparing for What’s Next: Treasury and IRS Guidance Priorities for Not-For-Profit Organizations

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released their 2026-2027 Priority Guidance Plan on September 29, 2026. The plan’s 121 projects include reporting and private foundation grantmaking.

The plan now follows the federal fiscal year, covering October 1, 2026, through September 30, 2027. Inclusion on the Priority Guidance Plan does not mean a rule is final or that guidance will be issued this year or in the immediate future.

The potential impact will vary considerably by organization type. Fiscal sponsorship programs, private foundations, higher education institutions and other tax-exempt organizations should evaluate the projects most relevant to them and consider how future guidance could affect them.

Key Areas for Tax-Exempt Organizations to Monitor

Fiscal Sponsors and Sponsored Projects

Donor-Advised Fund Sponsors

Private Foundation Grantmaking

Higher Education Investment-Income Tax

Private Schools and Scholarship-Granting Organizations

Political Campaign Guidance

Group-Exemption Networks

Thinking Ahead (Cautiously)

The Priority Guidance Plan provides a roadmap of where the Treasury and IRS intend to focus their attention, but it should not be treated as a set of new requirements. For tax-exempt organizations, the immediate priority is to understand which potential developments could affect them organization and what those developments may mean. Organizations that understand their potential areas of impact now will be better positioned to make informed decisions and respond efficiently if final guidance is issued.

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Have Questions or Need Guidance?

Withum’s Not-for-Profit Services Team can help organizations assess which projects may be most relevant, evaluate potential implications and develop a proportionate strategy for future guidance.

Contact Us

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