On July 31, 2015, the IRS released its 2015 - 2016 Priority Guidance Plan.  The list contains 277 projects that are priorities for allocation of IRS resources through June of 2016. 

39 of the 277 priorities are in the international area.  We have identified several "new" priorities that were not on the 2014 - 2015 list.  The new priorities of particular interest include:

1. Guidance under §§877A(g)(4) and 7701(a)(50)(A) regarding relinquishing United States citizenship.
2. Regulations and other guidance under §§6039F, 6048, and 6677 on foreign trust reporting and reporting with respect to foreign gifts, and under §§643(i) and 679 relating to certain transactions between U.S. persons and foreign trusts.
3. Regulations and other guidance under §7701, including guidance regarding entity classification and guidance treating disregarded entities as corporations for purposes of reporting and recordkeeping obligations under §6038A and related provisions.
4. Regulations on refunds and credits under Chapter 3 and Chapter 4. Notice 2015-10 was released on April 28, 2015.
5. Regulations regarding publicly traded partnerships under §1446 and Treas. Reg. §1.1446-4.
6. Guidance under §704(b) on the allocation by partnerships of foreign income tax.

Below is the complete list of the international items in the Priority Guidance Plan. 

Subpart F/Deferral

1. Guidance under §954(c), including regarding foreign currency gains.
2. Guidance under §954, including regarding foreign base company sales and services income.
3. Regulations under §956 regarding the treatment of loans to foreign partnerships and related issues.
4. Final regulations on the treatment of upfront payments on swaps under §956. Temporary and proposed regulations were published on May 8, 2015.
5. Final regulations under §959 on previously taxed earnings and profits. Proposed regulations were published on August 29, 2006.
6. Final regulations under §964 on accounting method elections. Proposed regulations were published on November 3, 2011.
7. Guidance under §§1295, 1297, and 1298 on passive foreign investment companies. Proposed regulations regarding foreign insurance companies were published on April 24, 2015. Temporary and proposed regulations regarding reporting requirements were published on December 31, 2013.

Inbound Transactions

1. Guidance under §864 implementing Revenue Ruling 91-32 relating to sales of certain partnership interests.
2. Regulations under §871(m) on dividend equivalent payments. Final and proposed regulations were published on December 5, 2013.
3. Regulations under §892. Proposed regulations were published on November 3, 2011.
4. Regulations regarding publicly traded partnerships under §1446 and Treas. Reg. §1.1446-4.
5. Proposed regulations under §6038C on information with respect to foreign corporations engaged in a U.S. trade or business.

Outbound Transactions

1. Regulations and other guidance under §367. Final, temporary, and proposed regulations were published on March 19, 2013, regarding outbound property transfers by domestic corporations. Notice 2014-32, regarding triangular reorganizations involving foreign corporations, was released on April 25, 2014.
2. Regulations under §367(d) regarding transfers of intangible property to foreign corporations and partnerships, including temporary and proposed regulations to implement Notice 2012-39.
3. Regulations under §7874. Temporary and proposed regulations were published on January 17, 2014, regarding stock that is disregarded for purposes of measuring stock ownership.
4. Regulations under §§7874, 367, 956, 7701(l), and 304 regarding inversions and related transactions. Notice 2014-52 was released on September 22, 2014.

Foreign Tax Credits

1. Guidance under §704(b) on the allocation by partnerships of foreign income tax.
2. Guidance under §901, including on the allocation of foreign tax imposed on disregarded entities and partnerships.
3. Regulations under §901(m) on covered asset acquisitions. Notices 2014-44 and 2014-45 were released July 21, 2014, and July 29, 2014.
4. Regulations under §904(d)(6) on the separate application of the foreign tax credit limitation to items resourced under treaties.
5. Guidance under §905, including final regulations under §905(c) on foreign tax redeterminations. Temporary and proposed regulations were published on November 7, 2007.

Transfer Pricing

1. Guidance under §482, including with respect to the treatment and allocation of risk.
2. Annual Report on the Advance Pricing Agreement Program.
3. Revenue procedure updating Revenue Procedure 2006-9, as amended by Revenue Procedure 2008-31, on the Advance Pricing and Mutual Agreement Program. Notice 2013-79 was released November 22, 2013.

Sourcing and Expense Allocation

1. Regulations and other guidance under §861 regarding the allocation and apportionment of interest expense.
2. Regulations under §§861, 862, and 863(a) on the character and source of income, including income arising in transactions involving intellectual property and the provision of digital goods and services.

Treaties

1. Guidance under §894 and treaties, including regarding the application of various treaty provisions to hybrid entities and instruments.
2. Revenue procedure updating Revenue Procedure 2006-54 on procedures for taxpayers requesting Competent Authority assistance. Notice 2013-78 was released November 22, 2013.

Other

1. Guidance under §§877A(g)(4) and 7701(a)(50)(A) regarding relinquishing United States citizenship.
2. Regulations under §937(a), including regulations on the "presence test" for bona fide residence in U.S. territories.
3. Regulations under §987. Proposed regulations were published on September 7, 2006.
4. Guidance on §988 transactions, including hedging transactions. Temporary and proposed regulations were published on September 6, 2012.
5. Guidance under Chapter 3 (§§1441-1446) and under Chapter 4 (§§1471-1474). Revenue Procedure 2014-47 was published on August 25, 2014.
6. Regulations on refunds and credits under Chapter 3 and Chapter 4. Notice 2015-10 was released on April 28, 2015.
7. Final regulations under §5000C relating to specified Federal procurement payments received by foreign persons from the U.S. government. Proposed regulations were published on April 22, 2015.
8. Regulations under §§6011 and 6038 relating to the country-by-country reporting of income, earnings, taxes paid, and certain economic activity for transfer pricing risk assessment.
9. Final regulations under §6038D regarding domestic entities holding specified foreign financial assets. Proposed regulations were published on December 19, 2011.
10. Regulations and other guidance under §§6039F, 6048, and 6677 on foreign trust reporting and reporting with respect to foreign gifts, and under §§643(i) and 679 relating to certain transactions between U.S. persons and foreign trusts.
11. Regulations and other guidance under §7701, including guidance regarding entity classification and guidance treating disregarded entities as corporations for purposes of reporting and recordkeeping obligations under §6038A and related provisions.