Bulletin No. 2022–33

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2022–33

August 15, 2022

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

Rev. Proc. 2022-29, page 141.

This revenue procedure modifies and supersedes Revenue Procedure 2006-36, 2006-38 I.R.B 498. It sets

forth the procedures for other Government agencies

and members of the public to request the creation of

special statistical studies and compilations involving

return information pursuant to section 6108(b) of the

Internal Revenue Code. It further sets forth the criteria

for determining reasonable fees for costs associated

with the creation of the special statistical studies and

compilations.

Rev. Proc. 2022-34, page 143.

This revenue procedure provides indexing adjustments

for certain provisions under § 36B of the Internal

Finding Lists begin on page ii.

Revenue Code (Code). In particular, it updates the

applicable percentage table in § 36B(b)(3)(A)(i) used to

calculate an individual’s premium tax credit for calendar

year 2023. The revenue procedure also updates the

required contribution percentage in § 36B(c)(2)(C)(i)(II)

for plan years beginning after calendar year 2022. This

percentage is used to determine whether an individual

is eligible for affordable employer-sponsored minimum

essential coverage under § 36B.

EXEMPT ORGANIZATIONS

Announcement 2022-16, page 144.

Revocation of IRC 501(c)(3) Organizations for failure

to meet the code section requirements. Contributions

made to the organizations by individual donors are no

longer deductible under IRC 170(b)(1)(A).

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

August 15, 2022 

Bulletin No. 2022–33

Part III

26 U.S.C. 6108(b): Special Statistical Studies

Rev. Proc. 2022-29

SECTION 1. PURPOSE

This revenue procedure modifies and

supersedes Rev. Proc. 2006-36, 200638 I.R.B. 498 (September 18, 2006) to

update the procedures for other Government agencies or members of the public

to request the Internal Revenue Service

(IRS) to create special statistical studies and compilations involving return

information pursuant to § 6108(b) of the

Internal Revenue Code (Code), and to set

forth the criteria for determining reasonable fees for costs associated with the creation of the special statistical studies and

compilations.

SECTION 2. NATURE OF CHANGES

.01 Section 2.01 of Rev. Proc. 2006-36

is updated as follows:

(1) To describe the IRS’s authority to

prescribe reasonable fees for the cost of

work or services performed to create special statistical studies and compilations.

(2) To clarify that fees are charged only

for a special statistical study or compilation that does not primarily benefit the

public.

.02 Section 2.02(c)(ii) of Rev. Proc.

2006-36 is revised to update the list of

electronic medium that are currently

used by the offices processing requests

to create special statistical studies and

compilations.

.03 Section 3.02 of Rev. Proc. 2006-36

is revised:

(1) To reflect that requests to create

special statistical studies and compilations

may be submitted by mail or email and

must be addressed to the Director, Statistics of Income Division (SOI).

(2) To reflect a new address, phone

number, and fax number for SOI.

(3) To remove the last sentence providing that a determination to grant or

deny requests to create special statistical

studies and compilations will be made in

consultation with the Director, Office of

Tax Analysis, Department of the Treasury (Treasury Department), if a significant amount of SOI resources are needed

to accommodate a request. The Office of

Tax Analysis, Treasury Department is not

involved in determining whether to grant

or deny requests to create special statistical studies and compilations because SOI

is recognized by the Director of the Office

of Management and Budget (OMB) as a

principal Federal statistical agency and

therefore is required to develop its own

policies regarding statistical releases.

See Title III of the Foundations For Evidence-Based Policymaking Act of 2018,

Public Law 115–435, 132 Stat. 5529,

5544- 5555 (44. U.S.C. §§ 3561-3583).

.04 Section 5.01 of Rev. Proc. 2006-36

is updated to reflect that fees are charged

to create special statistical studies and

compilations only for a special statistical

study or compilation that does not primarily benefit the public.

SECTION 3. BACKGROUND

.01 In general. Under § 6108(b), the

IRS may, upon written request, create

and produce special statistical studies

and compilations involving return information (as defined by § 6103(b)(2) of the

Code). In processing requests for special

statistical studies and compilations, the

IRS, pursuant to § 6108(c), will not disclose information that could, directly or

indirectly, be associated with or identify a

particular taxpayer. Pursuant to its authority under § 6108(b), the IRS may charge

a reasonable fee for the cost of work or

services associated with making special

statistical studies and compilations. Consistent with § 6(a)(1) of OMB Circular

A-25,1 fees will be charged only for a

special statistical study or compilation

that does not primarily benefit the public.

A special statistical study or compilation

that primarily benefits the public provides

statistical information about the Federal

tax system that is deemed pertinent and

valuable to the public and can be published in conjunction with the IRS’s publication of statistics pursuant to § 6108(a).

The IRS will determine the amount of the

fee as discussed in section 6 of this revenue procedure.

.02 Definitions.

(1) A “special statistical study” is an ad

hoc statistical examination or analysis of

return information that generally requires

new programming and analysis according

to specifications provided in the request.

A special statistical study might comprise tabulations as well as accompanying

reports on methodology and analytical

details.

(2) A statistical “compilation” is an ad

hoc accumulation of existing (or readily available) data into a data set or data

file, which generally requires new programming according to specifications

provided in the request. Both special statistical studies and compilations will be

reviewed for accuracy by IRS staff before

they are considered completed. The IRS

staff, including technical, administrative,

and computer programming personnel,

will ensure, as reasonably practicable, that

the completed special statistical study or

compilation reflects the specifications of

the original request.

(3) A special statistical study or compilation is not (i) statistical data contained in reports or releases already made

available to the public, or (ii) statistical

data that is readily reproducible. “Readily reproducible” means, with respect to

electronic format, a record or records that

can be downloaded or transferred intact to

a universal serial bus (USB) flash drive,

digital versatile disc (DVD), compact disk

(CD), or other electronic medium using

equipment currently in use by the office

or offices processing the request. Records

1

As relevant to charging user fees, OMB Circular A-25 cites as its authority Title V of the Independent Offices Appropriations Act, 1952 (Public Law 37, 65 Stat. 268, 290 (1951)), codified

at 31 U.S.C. 9701 by “A bill to revise, codify, and enact without substantive change certain general and permanent laws, related to money and finance, as title 31, United States Code, ‘Money

and Finance’,” Public Law 97-258, 96 Stat. 877, 1051-1052 (1982).

Bulletin No. 2022–33

141

August 15, 2022

that require manipulation of data within a

database or several databases, reprogramming one or more databases, or analysis

of the data to produce the records, are not

readily reproducible.

SECTION 4. PROCEDURES

FOR REQUESTING SPECIAL

STATISTICAL STUDIES AND

COMPILATIONS PURSUANT TO §

6108(b)

.01 In general. Requests for special statistical studies or compilations (involving

either new projects or changes in recurring projects) must be submitted in writing with specifications as complete and

definite as practical. Specifications that

are concise and mutually understood by

the requester and the IRS are essential for

a project’s successful completion. Specifications should include the source and

availability of data and content, manner

of presentation (for example, particular

medium or application) and timing of

results (for example, scheduling).

.02 Submitting requests. All requests

for special statistical studies or compilations must be addressed to the Director,

SOI and emailed to SIS@IRS.GOV or

mailed to the following address:

Director, Statistics of Income Division

Internal Revenue Service

1111 Constitution Avenue, NW Room

K-4100

Washington, DC 20224

Attention: RAAS, Statistics of Income

The Director, SOI, will review all

requests for special statistical studies or

compilations and make a determination

whether to grant or deny the request for

such special statistical studies or compilations based on the considerations stated

in section 5.01 of this revenue procedure.

If a significant amount of resources are

needed to accommodate a request, such

determination will be made in consultation with the responsible IRS offices.

.03 Consultation with SOI. If assistance

is needed, SOI’s Statistical Information

Services Office is available to help the

requester in detailing the specifications

of the request for a special study or compilation. Consultations at initial stages,

that is, while planning by the requester is

underway, may facilitate the undertaking

of a special study or compilation. In some

August 15, 2022

instances, initial consultation may reveal

that an existing IRS product contains all

the data necessary to fulfill the request.

SOI’s Statistical Information Services

Office may be reached by email at SIS@

IRS.GOV, by phone at (202) 803-9285

(not a toll-free number), by fax at (202)

803-9393, or by mail at the address provided in section 4.02 of this revenue procedure. In addition, there is information

available on the IRS website at irs.gov/

statistics.

SECTION 5. AVAILABILITY OF

SPECIAL STATISTICAL STUDIES

AND COMPILATIONS

.01 The fulfillment of requests for special statistical studies or compilations submitted pursuant to this revenue procedure

will be subject to several factors, including

staff availability and workload, the complexity and/or magnitude of the request,

the impact on tax administration, software

capabilities, database configurations and

equipment functionalities, and disclosure

considerations. A request will be declined

if the IRS determines at the time of the

initial request that the special statistical

study or compilation could reveal return

information or other taxpayer identifying

information, the disclosure of which is

not authorized by law, and no reconfiguration of the request can avoid disclosure

of return information or other non-disclosable data.

.02 If the configuration of an ongoing

special statistical study or compilation

may result in the disclosure of return

information, or if the identity of individual taxpayers can reasonably be inferred

by either direct or indirect means, the

IRS will inform the requester and offer to

discuss with the requester, to the extent

practicable, possible reconfigurations of

data to avoid the prohibited disclosure.

If the special statistical study or compilation cannot be adequately reconfigured,

the requester will be so informed, and the

special statistical study or compilation

will not be completed; nor will any information that has already been compiled be

released.

.03 In general, the IRS will consider

whether to grant or deny requests for special statistical studies and compilations in

the order of receipt.

142

SECTION 6. DETERMINATION OF

FEES

.01 Fees will be charged for a special

statistical study or compilation that does

not primarily benefit the public. The IRS

will determine whether a statistical study

or compilation primarily benefits the public. Fees will be determined in accordance

with prevailing Government standards,

but in no case will work be done before a

cost estimate is provided to the requester

and, if accepted, a reimbursable agreement is entered into between IRS and the

requester.

.02 Consistent with § 6(a)(1) and (d)

(1) of OMB Circular A-25, fees are based

on the actual, full cost of providing the

product or service. “Full cost” includes all

direct and indirect costs to any part of the

government of providing the special statistical study or compilation. These costs

include but are not limited to:

(1) direct costs such as computer costs,

salaries, management and supervisory

costs;

(2) indirect personnel costs such

as fringe benefits, for example, medical insurance and retirement (generally

assessed at a percentage of direct salary

costs); and

(3) physical overhead, consulting, and

other indirect costs such as material and

supply costs and utilities.

.03 The IRS may charge fees for any

costs incurred during the processing of

an accepted request for special statistical

studies and compilations.

SECTION 7. EFFECT ON OTHER

REVENUE PROCEDURES

Rev. Proc. 2006-36, 2006-38 I.R.B.

498, is superseded.

SECTION 8. EFFECTIVE DATE

This revenue procedure is effective on

August 1, 2022.

SECTION 9. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Robert Bley of the Office

of the Associate Chief Counsel (Procedure & Administration). However, other

Bulletin No. 2022–33

personnel from the IRS and the Treasury

Department participated in the development of the revenue procedure. For further information regarding this revenue

procedure contact Robert Bley at (202)

317-6834 (not a toll free number).

26 CFR 601.105: Examination of returns and claims

for refund, credit, or abatement; determination of

correct tax liability.

(Also Part 1, §§ 36B, 1.36B-2, 1.36B-3.)

Rev. Proc. 2022-34

SECTION 1. PURPOSE

This revenue procedure provides

indexing adjustments for certain provisions under § 36B of the Internal Revenue

Code (Code). In particular, it updates the

applicable percentage table in § 36B(b)

(3)(A)(i) (Applicable Percentage Table)

for calendar year 2023.1 This table is

used to calculate an individual’s premium

tax credit. The revenue procedure also

updates the required contribution percentage in § 36B(c)(2)(C)(i)(II) for plan

years beginning after calendar year 2022

(Section 36B Required Contribution Percentage). This percentage is used to determine whether an individual is eligible for

affordable employer-sponsored minimum

essential coverage under § 36B. This revenue procedure uses the methodology

described in section 4 of Rev. Proc. 201437, 2014-2 C.B. 363, to index the Applicable Percentage Table and the Section 36B

Required Contribution Percentage for calendar year 2023. The Applicable Percentage Table and the Section 36B Required

Contribution Percentage are indexed

based on the rates of premium growth relative to the rates of income growth. See §§

1.36B-2(c)(3)(v)(C) and 1.36B-3(g)(1) of

the Income Tax Regulations. The rates of

premium growth and the rates of income

Household income percentage of Federal poverty line:

Less than 133%

At least 133% but less than 150%

At least 150% but less than 200%

At least 200% but less than 250%

At least 250% but less than 300%

At least 300% but not more than 400%

.02 Section 36B Required Contribution Percentage for 2023. For plan years

beginning in calendar year 2023, the Section 36B Required Contribution Percentage for purposes of § 36B(c)(2)(C)(i)(II)

and § 1.36B-2(c)(3)(v)(C) is 9.12%.

SECTION 3. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 2014-37 is supplemented.

growth are determined using the National

Health Expenditure Accounts (NHEA)

Projections published by the Centers for

Medicare and Medicaid Services Office

of the Actuary.2 Rev. Proc. 2014-37, sections 3.01, 3.02. In addition, the additional

adjustment provided in § 36B(b)(3)(A)(ii)

(II) is not required for plan years beginning in 2023 because the Department of

the Treasury and the Internal Revenue

Service have determined that the failsafe

exception described in § 36B(b)(3)(A)(ii)

(III) applies for plan years beginning in

calendar year 2023.

SECTION 2. ADJUSTED ITEMS

.01 Applicable Percentage Table for

2023. For taxable years beginning in calendar year 2023, the Applicable Percentage Table for purposes of § 36B(b)(3)(A)

(i) and § 1.36B-3(g) of the Income Tax

Regulations is:

Initial percentage

1.92%

2.88%

3.84%

6.05%

7.73%

9.12%

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective for

taxable years and plan years beginning

after December 31, 2022.

Final percentage

1.92%

3.84%

6.05%

7.73%

9.12%

9.12%

Associate Chief Counsel (Income Tax

and Accounting). For further information

regarding this revenue procedure, contact

Mr. Ruane at (202) 317-4718 (not a tollfree number).

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Bill Ruane of the Office of

The American Rescue Plan Act of 2021, Public Law 117-2, 135 Stat. 4, 182 (2021), added § 36B(b)(3)(A)(iii) to the Code to provide an Applicable Percentage Table that applies for taxable

years beginning in calendar years 2021 and 2022. Section 36B(b)(3)(A)(iii) also suspends indexing of the Applicable Percentage Table for the 2021 and 2022 taxable years.

2

The rate of premium growth and the rate of income growth for calendar year 2023 are calculated using the NHEA Projections, 2021-2030, available at: https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected, which reflect the most recent projections, and the methodology used

to calculate the same rates of growth in the Premium Adjustment Percentage guidance for the 2023 benefit year published by the Center for Medicare and Medicaid Services on December

28, 2021, available at: https://www.cms.gov/files/document/2023-papi-parameters-guidance-v4-final-12-27-21-508.pdf.

1

Bulletin No. 2022–33

143

August 15, 2022

Part IV

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2022-16

Table of Contents

The Internal Revenue Service has

revoked its determination that the organizations listed below qualify as organizations described in sections 501(c)(3) and

170(c)(2) of the Internal Revenue Code of

1986.

Generally, the IRS will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the IRS is not precluded from disallowing a deduction for

any contributions made after an organization ceases to qualify under section 170(c)

(2) if the organization has not timely filed

a suit for declaratory judgment under section 7428 and if the contributor (1) had

knowledge of the revocation of the ruling

or determination letter, (2) was aware that

such revocation was imminent, or (3) was

in part responsible for or was aware of the

activities or omissions of the organization

that brought about this revocation.

Effective Date of

Revocation

NAME OF ORGANIZATION

Sasi, Inc.

AMERICAN FRIENDS OF THE JONATHAN INSTITUTE

United Lao Council for Peace Freedom and Reconstruction

Yale Club of Princeton, Inc.

Sherman Oaks Health System

Missouri Athletic Club Foundation for the Arts

CRYSTAL LAKE COUNTRY CLUB

Mercy Foundation Group, Inc.

Community Link Foundation, Inc.

Service Dogs by Warren Retrievers, Inc.

Creating A New Outlook, Inc.

WEST COAST CHARITY FOR THE CHILDREN

Cancer Support Services

Maritime Pilots Institute

Sisterhood on the Move Inc.

Marilyn Jane Foundation

Batchu Foundation

Giles County Partnership for Excellence

High Rising Equine Rescue, Inc.

Miyb California

Save Our Children USA, Inc.

August 15, 2022

If on the other hand a suit for declaratory judgment has been timely filed,

contributions from individuals and organizations described in section 170(c)(2)

that are otherwise allowable will continue to be deductible. Protection under

section 7428(c) would begin on August

15, 2022 and would end on the date the

court first determines the organization is

not described in section 170(c)(2) as more

particularly set for in section 7428(c)(1).

For individual contributors, the maximum

deduction protected is $1,000, with a husband and wife treated as one contributor.

This benefit is not extended to any individual, in whole or in part, for the acts or

omissions of the organization that were

the basis for revocation.

1/1/2017

3/1/2017

1/1/2017

4/1/2017

2/1/2017

9/1/2016

6/23/2021

1/1/2015

1/1/2018

1/1/2017

1/1/2018

1/1/2017

1/1/2014

1/1/2018

1/1/2017

6/4/2014

2/6/2017

7/1/2016

1/1/2016

1/1/2016

1/1/2017

144

LOCATION

Lake Grove, NY

New York, NY

Sacramento, CA

Princeton, NJ

Los Angeles, CA

Saint Louis, MO

Crystal Lake, IL

Tampa, FL

Manchester, MI

Culpepper, VA

Milwaukee, WI

Grants Pass, OR

Nashville, TN

Covington, LA

Mattapan, MA

Lake Orion, MI

Downers Grove, IL

Glen Lyn, VA

Estell Manor, NJ

Santa Maria CA

Saint Cloud, FL

Bulletin No. 2022–33

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2022–33

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

August 15, 2022

Numerical Finding List1

Bulletin 2022–33

Announcements:

2022-14, 2022-31 I.R.B. 136

2022-15, 2022-31 I.R.B. 136

2022-16, 2022-33 I.R.B. 144

Notices:

2022-29, 2022-28 I.R.B. 66

2022-30, 2022-28 I.R.B. 70

2022-31, 2022-29 I.R.B. 85

2022-32, 2022-32 I.R.B. 137

Proposed Regulations:

REG-130975-08, 2022-28 I.R.B. 71

REG 130675-17, 2022-30 I.R.B. 104

Revenue Procedures:

2022-25, 2022-27 I.R.B. 3

2022-28, 2022-27 I.R.B. 65

2022-26, 2022-29 I.R.B. 90

2022-32, 2022-30 I.R.B. 101

2022-30, 2022-31 I.R.B. 112

2022-29, 2022-33 I.R.B. 141

2022-34, 2022-33 I.R.B. 143

Revenue Rulings:

2022-12, 2022-27 I.R.B. 1

2022-13, 2022-30 I.R.B. 99

2022-14, 2022-31 I.R.B. 110

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin

2021–52, dated December 27, 2021.

1

August 15, 2022

ii

Bulletin No. 2022–33

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–33

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin

2021–52, dated December 27, 2021.

1

Bulletin No. 2022–33

iii

August 15, 2022

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

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