Treasury’s New Tax Plan Reflects NAM Advocacy

The Treasury Department has released its annual Priority Guidance Plan for 2026–2027, identifying which tax issues should be addressed through regulations, notices and other procedures. The plan indicates where the IRS and Treasury will focus their resources over the coming year.

NAM at work: The NAM provided extensive comments to the IRS on manufacturers’ tax priorities, which were reflected in the new Priority Guidance Plan. Some highlights include the following:

• Facility expensing: The NAM urged Treasury and the IRS to finalize guidance for Section 168(n), which allows immediate expensing of qualified production facilities, while expanding eligibility for dual-use infrastructure and including mixed-use spaces related to the manufacturing process, among other pro-manufacturing changes.
• R&D support: The NAM called on the agencies to enable manufacturers to claim the full accelerated amounts under Section 174(a) for research expensing. It also recommended updating and simplifying Form 6765 for the R&D tax credit, as well as reexamining the regulations governing compliance procedures and qualifying expenses for the credit.
• Gross deduction-eligible income: The NAM sought—and received—important changes to what qualifies as gross deduction-eligible income, ensuring the tax code better reflects manufacturers’ income and expenses.
• Carbon capture: The NAM advised the IRS to update regulatory guidance on Section 45Q, as carbon capture, utilization and storage projects continue to proliferate.

The last word: “The NAM is grateful for the continued efforts of the Department of the Treasury and the IRS to implement the pro-growth tax code established in H.R. 1,” said NAM Senior Director of Tax Policy Connor Rabb and NAM Vice President of Domestic Policy Jake Kuhns.

• “These actions are well-aligned with President Trump’s prioritization of manufacturing in America. By continuing to address the priority guidance of manufacturers outlined in this letter, Treasury can help continue the momentum to expand manufacturing in the United States and strengthen the foundation of American economic prosperity.”