n-22-21.pdf

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Public Recommendations Invited on Items to be Included on the 2022-2023 Priority
Guidance Plan

Notice 2022-21

The Department of the Treasury (Treasury Department) and the Internal
Revenue Service (IRS) invite the public to submit recommendations for items to be
included on the 2022-2023 Priority Guidance Plan.
The Treasury Department's Office of Tax Policy and the IRS 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 2022-2023 Priority Guidance Plan will identify
guidance projects that the Treasury Department and the IRS intend to actively work on
as priorities during the period from July 1, 2022, through June 30, 2023.
The Treasury Department and the IRS re cognize the importance of public input
in formulating 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 IRS have the benefit of the experience and knowledge of taxpayers
and practitioners who must apply the rules implementing the tax laws.

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This solicitation reflects an emphasis on taxpayer engagement with the Treasury
Department and the IRS through a variety of channels, consistent with the directive of
the Taxpayer First Act, Pub. L. 116-25, 133 Stat. 981.
In reviewing recommendations and selecting additional projects for inclusion on
the 2022-2023 Priority Guidance Plan, the Treasury Department and the IRS will
consider the following:
1. Whether the recommended guidance resolves significant issues relevant to a
broad class of taxpayers;
2. Whether the recommended guidance reduces controversy and lessens the
burden on taxpayers or the IRS;
3. Whether the recommended guidance relates to recently enacted legislation;
4. Whether the recommendation involves existing regulations or other guidance
that is outdated, unnecessary, ineffective, insufficient, or unnecessarily
burdensome and that should be modified, streamlined, expanded, replaced,
or withdrawn;
5. Whether the recommended guidance promotes sound tax administration;
6. Whether the IRS can administer the recommended guidance on a uniform
basis; and
7. Whether the recommended guidance can be drafted in a manner that will
enable taxpayers to easily understand and apply the guidance.
Please submit recommendations for guidance by Friday, June 3, 2022, for
possible inclusion on the original 2022-2023 Priority Guidance Plan. Taxpayers may,
however, submit recommendations for guidance at any time during the year. The

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Treasury Department and the IRS will update the 2022-2023 Priority Guidance Plan
periodically to reflect additional guidance that the Treasury Department and the IRS
intend to publish or have published during the plan year. The periodic updates allow the
Treasury Department and the IRS to respond in a timely manner 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. For recommendations to modify,
streamline, or withdraw existing regulations or other guidance, taxpayers should explain
how the changes would reduce taxpayer cost and/or burden or benefit tax
administration. 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 by subject matter and
then 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 are strongly encouraged to submit recommendations for guidance
electronically via the Federal eRulemaking Portal at www.regulations.gov
(type IRS-
2022-0 007 in the search field on the regulations.gov homepage to find this notice and
submit recommendations).
Taxpayers submitting recommendations by mail should
send them to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2022-21) Room 5203

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P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

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 the Associate
Chief Counsel (Procedure and Administration) at (202) 317-5409 (not a toll-free call).