The American Institute of CPAs (AICPA) has submitted comments to the Internal Revenue Service (IRS) setting out recommendations regarding the 2026–27 Priority Guidance Plan.
The submission follows a request from the Department of the Treasury and the IRS inviting public recommendations for items to be included in the plan.
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The Priority Guidance Plan is updated annually to identify and rank tax issues that should be tackled through regulations, revenue rulings, revenue procedures, notices and other forms of published administrative guidance.
The 2026–27 plan will cover projects the Treasury Department and the IRS intend to actively pursue as priorities between 1 July 2026 and 30 June 2027.
AICPA recommendations draw on input from ten technical panels.
These panels cover Corporations and Shareholders; Employee Benefits; Exempt Organizations; Individual and Self-Employed; International; and IRS Advocacy & Relations.
The panels also cover Partnership; S Corporation; Tax Methods and Periods; Tax Practice Responsibilities; and Trust, Estate and Gift Tax.
In its letter, the AICPA asks the Department of the Treasury and the IRS to keep simplification at the centre of future guidance projects.
At the same time, it acknowledges that rule-writers must weigh different policy aims and stakeholder perspectives when shaping regulations and other official interpretations.
The organisation urges the government to adopt the least complicated mechanism that still achieves a given policy objective.
The AICPA also calls for the inclusion of safe harbour options and the use of definitions that are applied in a clear and consistent way.
It also backs wider adoption of horizontal drafting, under which a rule formulated in one Internal Revenue Code provision would, where appropriate, be used in the same way in other Code sections.
It also encourages the IRS to build on existing guidance around record-keeping practices that are already standard across industries and businesses.
The complexity of any rule, the AICPA contends, should correspond to the sophistication and capacity of the taxpayers expected to follow it.
Overall, the AICPA’s submission included 193 recommendations.
AICPA Tax Policy and Advocacy director Kristin Esposito said: “The recommendations ensure that the IRS guidance reflects practical, real-world application for taxpayers and practitioners.
“Given that our recommendations are ranked by priority within each area, we encourage a focus on the highest-priority items.”
The AICPA recently revised an auditing standard intended to update the way practitioners obtain audit evidence from external sources.
