Treasury’s 2024-2025 Priority Guidance Plan

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) recently released the 2024-2025 Priority Guidance Plan, highlighting 231 critical guidance projects for the upcoming fiscal year, spanning from July 1, 2024, to June 30, 2025. The comprehensive plan addresses regulatory updates and new policies reflecting recent legislative changes, including initiatives under the Inflation Reduction Act and SECURE 2.0 Act. Additionally, public engagement plays a critical role in shaping this agenda, aligning with the Taxpayer First Act’s directive to prioritize taxpayer feedback.

1. Energy Security Initiatives

The plan includes robust measures to bolster the U.S. energy sector’s resilience and sustainability through several tax credits and deductions:

• Clean Energy Credits: Projects address the production of clean hydrogen (§45V) and clean fuel (§45Z), along with incentives for energy-efficient commercial buildings (§179D) and nuclear power production (§45U).
• Electric and Alternative Fuel Vehicles: Guidance for the alternative fuel vehicle credit (§30C) and the clean electricity investment credit (§48E) is under development, targeting increased adoption of green technology.
• Carbon Sequestration and Renewable Projects: The IRS will finalize guidance on carbon oxide sequestration credits (§45Q) and enhance the domestic content bonus credit (§45(b)(9)) to support U.S.-based manufacturing in clean energy.

2. Corporate and Shareholder Reforms

New regulations under Part 2 of Subtitle A of the Inflation Reduction Act focus on corporate stock repurchase taxes (§4501) and ownership provisions impacting consolidated groups:

• Stock Repurchase Taxation: Final regulations will clarify excise tax on corporate stock repurchases to prevent tax avoidance through buybacks.
• Consolidated Returns: Updates to §1502 rules will address multi-member partnerships and group continuity, reflecting statutory amendments to support complex corporate structures.
• International Corporate Transactions: Cross-border regulations under §367 address outbound intangible transfers, aligning U.S. policy with global anti-abuse standards.

3. Employee Benefits and Retirement Programs

Employee retirement and compensation benefits are central to the plan, especially under the SECURE 2.0 Act:

• Retirement Contributions and Compliance: The guidance under §§401(a), 408A, and 403(b) will adapt to facilitate employer-sponsored retirement plans, with a focus on compliance tools and streamlined reporting.
• Automatic Enrollment and Catch-Up Contributions: Expanded catch-up contribution provisions and mandatory automatic enrollment (§414A) aim to increase retirement savings, especially for lower-income workers.
• Student Loan Payment Benefits: Provisions are introduced for student loan payments to qualify for retirement contributions, providing new avenues for savings among younger workers.

4. Tax-Exempt Organizations

For tax-exempt organizations, the IRS plans to revise guidance affecting donations, operating expenses, and regulatory compliance:

• Donor-Advised Funds: Updates to §4966 and §4967 will strengthen oversight of donor-advised funds, addressing prohibited benefits and management responsibilities.
• SECURE 2.0 and 529 Plans: Modifications under the SECURE 2.0 Act will clarify tax treatments for §529 savings plans, benefitting education funding initiatives.
• Business Income Allocation: Regulatory changes will refine tax calculations on unrelated business income for exempt entities, promoting transparency.

5. Tax Treatment of Digital Assets

The Treasury will issue comprehensive rules on the taxation and reporting of digital assets, responding to growing cryptocurrency adoption and regulatory requirements from the Infrastructure Investment and Jobs Act:

• Digital Asset Reporting: New standards under §6045A and §6050I will formalize digital asset transaction reporting, impacting exchanges, brokers, and individual holders.
• Valuation and Compliance: Further regulations will define income characterization for tax purposes, addressing complex aspects such as token wrapping and valuation discrepancies in cryptocurrency transactions.

6. General Tax Issues and Innovation Support

The IRS will focus on modernization and support for domestic innovation, with plans targeting R&D credit qualifications, charitable contributions, and the opportunity zones program:

• Research and Development (R&D) Tax Credit: Regulations under §41 will refine R&D credit qualifications to simplify compliance and maximize support for high-tech industries.
• Opportunity Zones: Updates under §1400Z–1 and §1400Z–2 will address the usage of opportunity zones to encourage economic growth in underdeveloped areas.
• Conservation and Environmental Charitable Contributions: Revised rules for charitable conservation easements (§170) will clarify eligibility criteria for tax benefits on conservation-focused donations.

Conclusion

The 2024-2025 Priority Guidance Plan signals an aligning tax policy with economic, social, and environmental priorities. It seeks to streamline tax administration, promote taxpayer compliance, and adapt tax regulations to evolving economic landscapes. By integrating public feedback and addressing emerging challenges, the Treasury and IRS aim to create a more responsive, resilient, and inclusive tax system.