AICPA urges IRS tax simplification in 2026-2027 guidance plan

The AICPA’s latest push at the IRS is more than policy housekeeping for KPMG tax teams. Its 193 recommendations, submitted May 15 for the 2026-2027 Priority Guidance Plan, point to the issues most likely to turn into rework, deadline pressure, and client friction if the agency moves slowly.

The plan will run from July 1, 2026, through June 30, 2027, and the IRS opened the public recommendation process in Notice 2026-23 on March 23, setting a May 29 deadline for suggestions. The IRS says the annual guidance plan is meant to identify and prioritize tax issues for regulations, revenue rulings, revenue procedures, notices, and other published guidance. For practitioners, that matters because the agency has also said clearer guidance helps increase voluntary compliance by reducing ambiguity in tax law, the kind of ambiguity that can keep KPMG managers, directors, and partners tied up in follow-up calls, memo drafting, and issue resolution.

The AICPA said its list was organized through 10 technical panels, covering corporations and shareholders, employee benefits, exempt organizations, individuals and self-employed taxpayers, international issues, IRS advocacy and relations, partnerships, S corporations, tax methods and periods, and trusts, estates and gift tax. Those are not abstract categories inside a Big Four tax practice. They are the buckets that drive staffing, review cycles, and escalation when a client needs an answer before a filing deadline or a transaction closes.

That is where the labor impact lands most sharply. Partnership rules can trigger cascading revisions across returns and forecasts. Employee benefits questions can send teams back into plan design, payroll coordination, and disclosure work. International and cross-border items often mean more documentation, more coordination with local advisers, and more time spent reconciling competing rule sets. Exempt organizations, trusts and estates, and S corporation issues each create their own training burden because the rules change the way teams prepare, review, and explain filings. Kristin Esposito, director of AICPA Tax Policy and Advocacy, said the recommendations were meant to reflect practical, real-world application for taxpayers and practitioners.

The AICPA also pressed for simplification principles that would make the work less brittle: use the simplest approach possible, offer safe-harbor alternatives, keep definitions clear and consistent, build on existing recordkeeping practices, and match rule complexity to taxpayer sophistication. In practice, that is the difference between a rule a staff tax associate can apply once and a rule that bounces through multiple rounds of partner review because no one wants to own the interpretation.

The filing was not a one-off. In 2025, the AICPA recommended 183 changes to the prior year’s guidance plan, showing how the annual IRS list has become a recurring waypoint in the tax calendar. For KPMG, it is also a forecast: the issues the IRS deprioritizes now are often the ones that will show up later as training decks, client alerts, and late-night fixes when guidance finally lands.