As Simon said, in practice, picking a reference plane to start on is mostly down to personal preference; all you're really determining is which way you're going to be "normally" looking at the part. It has little to no affect on the finished model when you go to incorporate it into an Assembly (although it can be slightly annoying to have to reorient several copies of the same part during constraining, but you learn to think about that in advance with experience), and you're free to reorient it however you like when you go to create the first view in a Drawing.
If you're following a tutorial that's specifically asking you to "select XY plane" or "align to Z axis", then yeah it's probably going to get a little confusing. But really, you should be paying more attention to how the reference geometry they're asking you to select relates to the Part you're making, rather than just what it's called. As long as the geometry you're referencing suits the purpose, that's the only thing that's important.