IRS And Treasury Release 2025-2026 Priority Guidance Plan

Yesterday, the Internal Revenue Service (IRS) and the U.S. Department of the Treasury (Treasury) released the 2025-2026 Priority Guidance Plan specifying the areas that they intend to focus formal guidance efforts on for the next fiscal year. There are several items that potentially impact section 501(c) organizations including:

1. Section 501(c)(3) Issues
   1. Guidance on the application of the fundamental public policy against racial discrimination, including consideration of recent case law, in determining the eligibility of private schools for recognition of tax-exempt status under §501(c)(3).
   2. Guidance on the statutory prohibition in §501(c)(3) against participation or intervention in political campaigns (the "Johnson Amendment").