n-20-47.pdf

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Public Recommendations Invited on Items to be Included on the 2020-2021 Priority
Guidance Plan

Notice 2020-47

The Department of the Treasury (Treasury Department) and the Internal
Revenue Service (Service) invite the public to submit recommendations for items to be
included on the 2020-2021 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 2020-2021 Priority Guidance Plan will identify
guidance projects that the Treasury Department and the Service intend to actively work
on as priorities during the period from July 1, 2020, through June 30, 2021.
The Treasury Department and the Service recognize 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 Service 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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In reviewing recommendations and selecting additional projects for inclusion on
the 2020-2021 Priority Guidance Plan, the Treasury Department and the Service 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 Service;
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that is outdated, unnecessary, ineffective, insufficient, or unnecessarily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or withdrawn;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 would be in accordance with
Executive Order 13771 (82 FR 9339), Executive Order 13777 (82 FR 12285),
Executive Order 13789 (82 FR 19317), or other executive orders.
6. Whether the recommended guidance promotes sound tax administration;
7. Whether the Service can administer the recommended guidance on a uniform
basis; and
8. 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 Wednesday, July 22, 2020, for
possible inclusion on the original 2020-2021 Priority Guidance Plan. Taxpayers may,

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however, submit recommendations for guidance at any time during the year. The
Treasury Department and the Service will update the 2020-2021 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 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-
2020-0015 in the search field on the regulations.gov homepage to find this notice and
submit recommendations). The IRS expects to have limited personnel available to
process recommendations that are submitted on paper through the mail. Until further

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notice, any recommendations submitted on paper will be considered to the extent
practicable. Taxpayers submitting recommendations by mail should send them to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2020-47) Room 5203
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) 317-3400 (not a toll-free call).