n-15-27.pdf

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Public Comment Invited on Recommendations for 2015-2016 Priority Guidance Plan

Notice 2015-27
The Department of Treasury and Internal Revenue Service (Service) invite
public comment on recommendations for items that should be included on the 2015-
2016 Priority Guidance Plan.
The Treasury Department's Office of Tax Policy and the Service use the
Priority Guidance Plan each year to identify and prioritize the tax issues that should
be addressed through regulations, revenue rulings, revenue procedures, notices,
and other published administrative guidance. The 2015-2016 Priority Guidance Plan
will identify guidance projects that the Treasury Department and the Service intend
to work on actively as priorities during the period from July 1, 2015, through June 30,
2016. The Treasury Department and the Service recognize the importance of public
input to formulate a Priority Guidance Plan that focuses resources on guidance
items that are most important to taxpayers and tax administration. Published
guidance plays an important role in increasing voluntary compliance by helping to
clarify ambiguous areas of the tax law. The published guidance process is most
successful if the Treasury Department and the Service have the benefit of the
experience and knowledge of taxpayers and practitioners who must apply the rules
implementing the internal revenue laws.
As is the case whenever significant legislation is enacted, the Treasury
Department and the Service have continued to dedicate substantial resources during
the current plan year to published guidance projects necessary to implement the

provisions of various tax Acts that have been enacted over the past several years
including, but not limited to, the Hiring Incentives to Restore Employment Act, Pub.
L. No. 111-147, 124 Stat. 71, which was enacted on March 18, 2010; the Patient
Protection and Affordable Care Act, Pub. L. No. 111-148, 124 Stat. 119, which was
enacted on March 23, 2010; the Health Care and Education Reconciliation Act, Pub.
L. No. 111-152, 124 Stat. 1029, which was enacted on March 30, 2010; the
Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113–
235, 128 Stat. 2130 (which includes the Expatriate Health Coverage Clarification Act
of 2014 (Division M) and the Multiemployer Pension Reform Act of 2014 (Division
O)), enacted on December 16, 2014; and the Tax Increase Prevention Act of 2014,
Pub. L. No. 113-295, 128 Stat. 4010 (which includes the Tax Technical Corrections
Act of 2014 and the Achieving a Better Life Experience Act of 2014), enacted on
December 19, 2014. The Treasury Department and the Service will continue to
evaluate the priority of each guidance project in light of the above-mentioned tax
legislation and other developments occurring during the 2015-2016 plan year.
In reviewing recommendations and selecting projects for inclusion on the 2015-
2016 Priority Guidance Plan, the Treasury Department and the Service will consider
the following:
1. Whether the recommended guidance resolves significant issues relevant to many
taxpayers;
2. Whether the recommended guidance promotes sound tax administration;
3. Whether the recommended guidance can be drafted in a manner that will enable
taxpayers to easily understand and apply the guidance;

4. Whether the recommended guidance involves regulations that are outmoded,
ineffective, insufficient, or excessively burdensome and that should be modified,
streamlined, expanded, or repealed;
5. Whether the Service can administer the recommended guidance on a uniform
basis; and
6. Whether the recommended guidance reduces controversy and lessens the
burden on taxpayers or the Service.
Please submit recommendations by May 1, 2015, for possible inclusion on the
original 2015-2016 Priority Guidance Plan. Taxpayers may, however, submit
recommendations for guidance at any time during the year. The Treasury
Department and the Service may update the 2015-2016 Priority Guidance Plan
periodically to reflect additional guidance that the Treasury Department and the
Service intend to publish during the plan year. The periodic updates allow the
Treasury Department and the Service to respond to the need for additional guidance
that may arise during the plan year.
Taxpayers are not required to submit recommendations for guidance in any
particular format. Taxpayers should, however, briefly describe the recommended
guidance and explain the need for the guidance. In addition, taxpayers may include
an analysis of how the issue should be resolved. It would be helpful if taxpayers
suggesting more than one guidance project prioritize the projects by order of
importance. If a large number of projects are being suggested, it would be helpful if
the projects were grouped in terms of high, medium, or low priority. Requests for
guidance in the form of petitions for rulemaking will be considered with other

recommendations for guidance in accordance with the considerations described in
this notice.
Taxpayers may mail comments to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2015-27)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

or hand deliver comments Monday through Friday between the hours of 8 a.m. and
4 p.m. to:
Courier's Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2015-27)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224

Alternatively, taxpayers may submit comments electronically via the Federal
eRulemaking Portal at www.regulations.gov
(type IRS-2015-0008 in the search field
on the regulations.gov homepage to find this notice and submit comments). All
recommendations for guidance submitted by the public in response to this notice will
be available for public inspection and copying in their entirety.
For further information regarding this notice, contact Emily M. Lesniak of the
Office of Associate Chief Counsel (Procedure and Administration) at (202) 317-3400
(not a toll-free call).