Bulletin No. 2022–50

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2022–50

December 12, 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, INCOME TAX

Rev. Proc. 2022-41, page 527.

This revenue procedure specifies when information

shown on a return in accordance with the applicable

forms and instructions will be an adequate disclosure

for purposes of reducing an understatement of income

Finding Lists begin on page ii.

tax under section 6662(d) and for purposes of avoiding the section 6694(a) preparer penalty. This revenue

procedure updates Rev. Proc. 2021-52, 2021-51 I.R.B.

883, and applies to any income tax return filed on 2022

tax forms for a taxable year beginning in 2022, and to

any income tax return filed in 2023 on 2022 tax forms

for short taxable years beginning in 2023.

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.

December 12, 2022 

Bulletin No. 2022–50

Part III

26 CFR 601.105: Examination of returns and claims

for refund, credit or abatement; determination of

correct tax liability.

(Also: Part 1, §§ 6662, 6694, 1.6662-4, 1.6694-2)

Adequate Disclosure

Revenue Procedure

Renewal

Rev. Proc. 2022-41

SECTION 1. PURPOSE

This revenue procedure updates Rev.

Proc. 2021-52, 2021-51 I.R.B. 883, and

identifies circumstances under which the

disclosure on a taxpayer’s income tax

return with respect to an item or position

is adequate for the purpose of reducing

the understatement of income tax under

section 6662(d) of the Internal Revenue

Code (relating to the substantial understatement aspect of the accuracy-related

penalty), and for the purpose of avoiding the tax return preparer penalty under

section 6694(a) (relating to understatements due to unreasonable positions)

with respect to income tax returns. This

revenue procedure does not apply with

respect to any other penalty provisions

(including but not limited to the disregard provisions of the section 6662(b)

(1) accuracy-related penalty, the section

6662(i) increased accuracy-related penalty in the case of nondisclosed noneconomic substance transactions, and

the section 6662(b)(7) and (j) increased

accuracy-related penalty in the case of

undisclosed foreign financial asset understatements). If this revenue procedure

does not include an item or position, disclosure is adequate with respect to that

item or position only if made on a properly completed Form 8275 or 8275-R, as

appropriate, attached to the return for the

year or to a qualified amended return. See

Treas. Reg. § 1.6664-2(c) for information

about qualified amended returns.

This revenue procedure applies to any

income tax return filed on 2022 tax forms

for a taxable year beginning in 2022, and

to any income tax return filed in 2023 on

2022 tax forms for short taxable years

beginning in 2023.

Bulletin No. 2022–50

SECTION 2. CHANGES FROM REV.

PROC. 2021-52

Changes have been made in order to

update the taxable years to which this revenue procedure applies. No substantive

changes have been made.

SECTION 3. BACKGROUND

.01 If section 6662 applies to any portion of an underpayment of tax required to

be shown on a return, an amount generally

equal to 20 percent of the portion of the

underpayment is added to the tax. Under

section 6662(b)(2), the penalty applies to

the portion of any underpayment of tax

that is attributable to a substantial understatement of income tax. The penalty rate

increases to 40 percent in the case of gross

valuation misstatements under section

6662(h), nondisclosed noneconomic substance transactions under section 6662(i),

or undisclosed foreign financial asset

understatements under section 6662(j).

.02 Generally, there is a substantial understatement of income tax if the

amount of the understatement exceeds

the greater of (i) 10 percent of the amount

of tax required to be shown on the return

for the taxable year or (ii) $5,000. Section

6662(d)(1). Section 6662(d)(1)(C) provides a special rule for taxpayers claiming

a section 199A deduction. In the case of

any taxpayer who claims any deduction

allowed under section 199A for the taxable year, there is a substantial understatement of income tax if the amount of the

understatement exceeds the greater of (i)

5 percent of the amount of tax required

to be shown on the return for the taxable

year or (ii) $5,000. Section 6662(d)(1)(B)

provides a special rule for corporations.

A corporation (other than an S corporation or a personal holding company) has

a substantial understatement of income

tax if the amount of the understatement

exceeds the lesser of (i) 10 percent of the

tax required to be shown on the return for

a taxable year (or, if greater, $10,000) or

(ii) $10,000,000. Generally, an understatement is the excess of the amount of

tax required to be shown on the return for

the taxable year over the amount of the

tax that is shown on the return reduced

527

by any rebate, where the excess is determined without regard to items to which

the reportable transaction understatement

penalty under section 6662A applies.

Section 6662(d)(2)(A). For purposes of

determining whether an understatement

is substantial, the understatement determined under the general rule is increased

by the aggregate amount of any reportable

transaction understatements relating to the

return. Section 6662A(e)(1)(A).

.03 In the case of an item not attributable to a tax shelter, if the taxpayer has a

reasonable basis for the tax treatment of

the item, the amount of the understatement is reduced by the portion of the

understatement attributable to the item

with respect to which the relevant facts

affecting the item’s tax treatment are

adequately disclosed in the return or in a

statement attached to the return. Section

6662(d)(2)(B)(ii).

.04 Section 6694(a) imposes a penalty

on a tax return preparer who prepares

a return or claim for refund reflecting

an understatement of liability due to an

“unreasonable position” if the tax return

preparer knew (or reasonably should have

known) of the position. A position (other

than a position with respect to a tax shelter

or a reportable transaction to which section 6662A applies) is generally treated

as unreasonable unless (i) there is or was

substantial authority for the position, or

(ii) the position was properly disclosed

in accordance with section 6662(d)(2)(B)

(ii)(I) and had a reasonable basis. If the

position is with respect to a tax shelter

(as defined in section 6662(d)(2)(C)(ii))

or a reportable transaction to which section 6662A applies, the position is treated

as unreasonable unless it is reasonable

to believe that the position would more

likely than not be sustained on the merits.

See Notice 2009-5, 2009-3 I.R.B. 309, for

interim penalty compliance rules for tax

shelter transactions.

.05 In general, this revenue procedure provides guidance for determining

when disclosure by return is adequate

for purposes of section 6662(d)(2)(B)(ii)

and section 6694(a)(2)(B). For purposes

of this revenue procedure, the taxpayer

must furnish all required information in

accordance with the applicable forms

December 12, 2022

and instructions, and the money amounts

entered on these forms must be verifiable.

.06 This revenue procedure may apply

to a return for a fiscal tax year that begins

in 2022 and ends in 2023. This revenue

procedure may also apply to a short year

return for a period beginning in 2023 if

the return is to be filed before the 2023

forms are available. (Note that individuals are generally not put in this position.)

The most frequent situation in which a

short year arises is when filing a decedent’s final return for a fractional part of a

year. In that situation, the 2023 form will

be available because the final return is

due the fifteenth day of the fourth month

following the close of the 12-month

period that began with the first day of

such fractional part of the year (meaning the due date is not accelerated). See

Treas. Reg. § 1.6072-1(b). In the case of

fiscal year and short year returns, the taxpayer must take into account any tax law

changes that are effective for tax years

beginning after December 31, 2022, even

though these changes are not reflected on

the form or instructions.

.07 This document does not take into

account the effect of tax law changes

effective for tax years beginning after

December 31, 2022. If a line referenced in

this revenue procedure is affected by such

a change and requires additional reporting,

a taxpayer may have to file Form 8275,

Disclosure Statement, or Form 8275-R,

Regulation Disclosure Statement, until the

Service prescribes criteria for complying

with the requirement.

.08 A complete and accurate disclosure

of a tax position on the appropriate year’s

Schedule UTP, Uncertain Tax Position

Statement, will be treated as if the corporation filed a Form 8275 or Form 8275-R

regarding the tax position. The filing of

a Form 8275 or Form 8275-R, however,

will not be treated as if the corporation

filed a Schedule UTP.

SECTION 4. PROCEDURE

.01 General

(1) Additional disclosure of facts relevant to, or positions taken with respect

to, issues involving any of the items

set forth below is unnecessary for purposes of reducing any understatement of

income tax under section 6662(d) (except

December 12, 2022

as otherwise provided in section 4.02(3)

concerning Schedules M-1 and M-3), provided that the forms and attachments are

completed in a clear manner and in accordance with their instructions.

(2) The money amounts entered on the

forms must be verifiable, and the information on the return must be disclosed in the

manner described below. For purposes of

this revenue procedure, a number is verifiable if, on audit, the taxpayer can prove

the origin of the amount (even if that

number is not ultimately accepted by the

Service) and the taxpayer can show good

faith in entering that number on the applicable form.

(3) The disclosure of an amount as

provided in section 4.02 below is not

adequate when the understatement arises

from a transaction between parties who

are related within the meaning of section

267(b). If an entry may present a legal

issue or controversy because of a related-party transaction, then that transaction

and the relationship must be disclosed on

a Form 8275 or Form 8275-R.

(4) When the amount of an item is

shown on a line that does not have a preprinted description identifying that item

(such as on an unnamed line under an

“Other Expense” category), the taxpayer

must clearly identify the item by including

the description on that line. For example,

to disclose a bad debt for a sole proprietorship, the words “bad debt” must be written

or typed on the line of Schedule C (Form

1040 or 1040SR) that shows the amount

of the bad debt. Also, for Schedule M-3

(Form 1120), Part II, line 25, Other income

(loss) items with differences, or Part III,

line 38, Other expense/deduction items

with differences, the entry must provide

descriptive language; for example, “Cost

of non-compete agreement deductible not

capitalizable,” and the description must be

provided on an attachment. Similarly, for

other forms, if space limitations on a form

do not allow for an adequate description,

the description must be continued on an

attachment.

(5) Although a taxpayer may literally

meet the disclosure requirements of this

revenue procedure, the disclosure will

have no effect for purposes of the section

6662 accuracy-related penalty if the item

or position on the return (1) does not have

a reasonable basis as defined in Treas.

528

Reg. § 1.6662-3(b)(3); (2) is attributable

to a tax shelter item as defined in section

6662(d)(2)(C)(ii); or (3) is not properly

substantiated or the taxpayer failed to

keep adequate books and records with

respect to the item or position.

(6) Disclosure also will have no effect

for purposes of the section 6694(a) penalty as applicable to tax return preparers if

the position is with respect to a tax shelter

(as defined in section 6662(d)(2)(C)(ii)) or

a reportable transaction to which section

6662A applies.

.02 Items

(1) Form 1040, Schedule A, Itemized

Deductions:

(a) Medical and Dental Expenses:

Complete lines 1 through 4, supplying all

required information.

(b) Taxes: Complete lines 5 through 7,

supplying all required information. Line 6

must list each type of tax and the amount

paid.

(c) Interest Expenses: Complete lines 8

through 10, supplying all required information. This section 4.02(1)(c) does not

apply to (i) amounts disallowed under section 163(d) unless Form 4952, Investment

Interest Expense Deduction, is completed,

or (ii) amounts disallowed under section

265.

(d) Charitable Contributions: Complete

lines 11 through 14, supplying all required

information and attaching all related forms

required pursuant to statute or regulation.

(e) Casualty and Theft Losses: Complete Form 4684, Casualties and Thefts,

and attach to the return. Each item or article for which a casualty or theft loss is

claimed must be listed on Form 4684.

(2) Certain Trade or Business Expenses

(including, for purposes of this section,

the following six expenses as they relate

to the rental of property):

(a) Casualty and Theft Losses: The

procedure outlined in section 4.02(1)(e)

must be followed.

(b) Legal Expenses: The amount

claimed must be stated. This section does

not apply, however, to amounts properly

characterized as capital expenditures, personal expenses, or non-deductible lobbying or political expenditures, including

amounts that are required to be (or that

are) amortized over a period of years.

(c) Specific Bad Debt Charge-off: The

amount written off must be stated.

Bulletin No. 2022–50

(d) Officers’ Compensation: Complete

Form 1125-E, Compensation of Officers,

when its instructions require completion.

You must express the “percent of time

devoted to business” as a numerical percentage, rather than as a non-numerical

description such as “part” or “as needed.”

This section does not apply to “excess

parachute payments,” as defined in section 280G. This section does not apply

to the extent that remuneration paid or

incurred exceeds an applicable employee-remuneration deduction limitation

under section 162(m).

(e) Repair Expenses: The amount

claimed must be stated. This section does

not apply, however, to any amount properly characterized as capital expenditures

or personal expenses.

(f) Taxes (other than foreign taxes):

The amount claimed must be stated.

(3) Differences in book and income tax

reporting:

For Schedule M-1 and all Schedules

M-3, including those listed in (a)-(f)

below, the information provided must

reasonably apprise the Service of the

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

potential controversy concerning the tax

treatment of the item. If the information

provided does not so apprise the Service, a

Form 8275 or Form 8275-R must be used

to adequately disclose the item (see Part II

of the instructions for those forms).

Note: An item reported on a line with

a pre-printed description, shown on

an attached schedule or “itemized”

on Schedule M-1, may represent the

aggregate amount of several transactions producing that item (i.e.,

a group of similar items, such as

amounts paid or incurred for supplies

by a taxpayer engaged in business).

In some instances, a potentially controversial item may involve a portion

of the aggregate amount disclosed on

the schedule. The Service will not be

reasonably apprised of a potential controversy by the aggregate amount disclosed. In these instances, the taxpayer

must use Form 8275 or Form 8275-R

regarding that portion of the item.

Combining unlike items, whether

on Schedule M-1 or Schedule M-3 (or

on an attachment when directed by the

instructions), will not constitute an adequate disclosure.

Additionally, taxpayers that file the

Schedule M-3 (Form 1120), Net Income

(Loss) Reconciliation for Corporations

With Total Assets of $10 Million or More,

may be required to complete Schedule B

(Form 1120), Additional Information for

Schedule M-3 Filers. For further information, see Who Must File in the General

Instructions for Schedule B (Form 1120).

Taxpayers that file the Schedule M-3

(Form 1065), Net Income (Loss) Reconciliation for Certain Partnerships, may be

required to complete Schedule C (Form

1065), Additional Information for Schedule M-3 Filers. For further information,

see Who Must File in the General Instructions for Schedule C (Form 1065). When

required, these schedules are necessary to

constitute adequate disclosure:

(a) Form 1065. Schedule M-3 (Form

1065), Net Income (Loss) Reconciliation

for Certain Partnerships:

Column (a), Income (Loss) per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Income (Loss) per Tax Return

Column (a), Expense per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Deduction per Tax Return

(b) Form 1120. (i) Schedule M-1, Reconciliation of Income (Loss) per Books With Income per Return.

(ii) Schedule M-3 (Form 1120), Net Income (Loss) Reconciliation for Corporations With Total Assets of $10 Million or More:

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

Bulletin No. 2022–50

Column (a), Income (Loss) per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Income (Loss) per Tax Return

Column (a), Expense per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Deduction per Tax Return

529

December 12, 2022

(c) Form 1120-L. Schedule M-3 (Form 1120-L), Net Income (Loss) Reconciliation for U.S. Life Insurance Companies With Total

Assets of $10 Million or More:

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

Column (a), Income (Loss) per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Income (Loss) per Tax Return

Column (a), Expense per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Deduction per Tax Return

(d) Form 1120-PC. Schedule M-3 (Form 1120-PC), Net Income (Loss) Reconciliation for U.S. Property and Casualty Insurance

Companies With Total Assets of $10 Million or More:

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

Column (a), Income (Loss) per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Income (Loss) per Tax Return

Column (a), Expense per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Deduction per Tax Return

(e) Form 1120-S. Schedule M-3 (Form 1120-S), Net Income (Loss) Reconciliation for S Corporations With Total Assets of $10

Million or More:

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

Column (a), Income (Loss) per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Income (Loss) per Tax Return

Column (a), Expense per Income Statement;

Column (b), Temporary Difference;

Column (c), Permanent Difference; and

Column (d), Deduction per Tax Return

(f) Form 1120-F. Schedule M-3 (Form 1120-F), Net Income (Loss) Reconciliation for Foreign Corporations With Reportable

Assets of $10 Million or More:

Part II (reconciliation of income

(loss) items)

Part III (reconciliation of

expense/deduction items)

December 12, 2022

Column (b), Temporary Differences;

Column (c), Permanent Differences; and

Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI

Column (b), Temporary Differences;

Column (c), Permanent Differences; and

Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI

530

Bulletin No. 2022–50

(4) Foreign Tax Items:

(a) International Boycott Transactions:

Transactions disclosed on Form 5713,

International Boycott Report; Schedule

A, International Boycott Factor (Section 999(c)(1)); Schedule B, Specifically

Attributable Taxes and Income (Section

999(c)(2)); and Schedule C, Tax Effect

of the International Boycott Provisions,

must be completed when required by their

instructions.

(b) Treaty-Based Return Position:

Transactions and amounts under section 6114 or section 7701(b) as disclosed

on Form 8833, Treaty-Based Return

Position Disclosure Under Section 6114

or 7701(b), must be completed when

required by its instructions.

(5) Other:

Bulletin No. 2022–50

(a) Moving Expenses: Complete Form

3903, Moving Expenses, and attach to the

return.

(b) Employee Business Expenses:

Complete Form 2106, Employee Business

Expenses (for use only by Armed Forces

reservists, qualified performing artists,

fee-basis state or local government officials,

and employees with impairment-related

work expenses), and attach to the return.

This section does not apply to club dues or

to travel expenses for any non-employee

accompanying the taxpayer on the trip.

(c) Fuels Credit: Complete Form 4136,

Credit for Federal Tax Paid on Fuels, and

attach to the return.

(d) Investment Credit: Complete Form

3468, Investment Credit, and attach to the

return.

531

SECTION 5. EFFECTIVE DATE

This revenue procedure applies to any

income tax return filed on a 2022 tax form

for a taxable year beginning in 2022 and

to any income tax return filed on a 2022

tax form in 2023 for a short taxable year

beginning in 2023.

SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Jesse Hubbard of the Office of

the Associate Chief Counsel (Procedure &

Administration). For further information

regarding this revenue procedure, contact

Branch 2 of Procedure and Administration

at (202) 317-6844 (not a toll free number).

December 12, 2022

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. 2022–50

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.

December 12, 2022

Numerical Finding List1

Bulletin 2022–50

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

2022-17, 2022-35 I.R.B. 179

2022-18, 2022-36 I.R.B. 190

2022-19, 2022-36 I.R.B. 191

2022-20, 2022-38 I.R.B. 238

2022-21, 2022-46 I.R.B. 464

2022-22, 2022-47 I.R.B. 497

2022-23, 2022-48 I.R.B. 499

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

2022-33, 2022-34 I.R.B. 147

2022-34, 2022-34 I.R.B. 150

2022-35, 2022-36 I.R.B. 184

2022-36, 2022-36 I.R.B. 188

2022-37, 2022-37 I.R.B. 234

2022-38, 2022-39 I.R.B. 239

2022-39, 2022-40 I.R.B. 264

2022-40, 2022-40 I.R.B. 266

2022-42, 2022-41 I.R.B. 276

2022-44, 2022-41 I.R.B. 277

2022-43, 2022-42 I.R.B. 303

2022-45, 2022-42 I.R.B. 307

2022-41, 2022-43 I.R.B. 304

2022-46, 2022-43 I.R.B. 306

2022-47, 2022-43 I.R.B. 312

2022-48, 2022-43 I.R.B. 316

2022-49, 2022-43 I.R.B. 321

2022-50, 2022-43 I.R.B. 325

2022-51, 2022-43 I.R.B. 331

2022-52, 2022-43 I.R.B. 337

2022-53, 2022-45 I.R.B. 437

2022-54, 2022-45 I.R.B. 439

2022-55, 2022-45 I.R.B. 443

2022-56, 2022-47 I.R.B. 480

2022-57, 2022-47 I.R.B. 482

2022-58, 2022-47 I.R.B. 483

2022-59, 2022-48 I.R.B. 498

2022-60, 2022-49 I.R.B. 502

2022-62, 2022-49 I.R.B. 506

Proposed Regulations:—Continued

REG-100719-21, 2022-45 I.R.B. 457

REG-121509-00, 2022-45 I.R.B. 463

REG-112096-22, 2022-49 I.R.B. 511

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

2022-35, 2022-40 I.R.B. 270

2022-36, 2022-40 I.R.B. 274

2022-19, 2022-41 I.R.B. 282

2022-31, 2022-43 I.R.B. 339

2022-37, 2022-43 I.R.B. 377

2022-38, 2022-45 I.R.B. 445

2022-40, 2022-47 I.R.B. 487

2022-39, 2022-49 I.R.B. 507

2022-41, 2022-50 I.R.B. 527

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

2022-15, 2022-35 I.R.B. 152

2022-17, 2022-36 I.R.B. 182

2022-18, 2022-40 I.R.B. 262

2022-19, 2022-44 I.R.B. 379

2022-20, 2022-45 I.R.B. 407

2022-21, 2022-47 I.R.B. 468

2022-22, 2022-49 I.R.B. 500

Treasury Decisions:

9963, 2022-34 I.R.B. 145

9964, 2022-35 I.R.B. 172

9965, 2022-37 I.R.B. 192

9966, 2022-44 I.R.B. 380

9967, 2022-44 I.R.B. 385

9968, 2022-45 I.R.B. 409

Proposed Regulations:

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

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

REG-125693-19, 2022-39 I.R.B. 241

REG-110368-22, 2022-44 I.R.B. 405

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

December 12, 2022

ii

Bulletin No. 2022–50

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–50

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. 2022–50

iii

December 12, 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

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.