Bulletin No. 2021–48

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2021–48

November 29, 2021

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. 2021-47, page 775.

This revenue procedure addresses the federal income tax

treatment and information reporting requirements for payments made to or on behalf of financially distressed individual homeowners by certain entities with funds allocated

from the Homeowner Assistance Fund (HAF), established

under section 3206 of the American Rescue Plan Act of

2021, Pub. L. No. 117-2, 135 Stat. 4 (March 11, 2021),

in response to the coronavirus disease (COVID-19) pandemic. This revenue procedure also provides guidance

to States, and mortgage lenders and servicers regarding

Finding Lists begin on page ii.

information reporting requirements relating to certain HAF

payments.

INCOME TAX

Rev. Proc. 2021-45, page 764.

This revenue procedure sets forth inflation-adjusted items for

2022 for various provisions of the Internal Revenue Code of

1986 (Code), as amended, as of November 10, 2021. To the

extent amendments to the Code are enacted for 2022 after

November 10, 2021, taxpayers should consult additional

guidance to determine whether these adjustments remain

applicable for 2022.

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.

November 29, 2021 

Bulletin No. 2021–48

Part III

26 CFR 601.602: Tax forms and instructions.

(Also Part I, §§ 1, 23, 24, 32, 36B, 42, 45R, 55, 59, 62, 63, 125, 132(f),135, 137, 146, 147, 148, 152, 179, 179D,199A, 213, 220, 221, 448, 461, 512, 513, 642, 831,

877, 877A, 911, 1274A, 2010, 2032A, 2503, 2523, 4161, 4261, 6033, 6039F, 6323, 6334, 6601, 6651, 6652, 6695, 6698, 6699, 6721, 6722, 7345, 7430, 7702B,

9831; 1.148-5.)

Rev. Proc. 2021-45

Table of Contents

SECTION 1. PURPOSE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 765

SECTION 2. CHANGES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 765

SECTION 3. 2022 ADJUSTED ITEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 765

Code Section

.01 Tax Rate Tables

.02 Unearned Income of Minor Children (“Kiddie Tax”)

.03 Maximum Capital Gains Rate

.04 Adoption Credit

.05 Child Tax Credit

.06 Earned Income Credit

.07 Refundable Credit for Coverage Under a Qualified Health Plan

.08 Rehabilitation Expenditures Treated as Separate New Building

.09 Low-Income Housing Credit

.10 Employee Health Insurance Expense of Small Employers

.11 Exemption Amounts for Alternative Minimum Tax

.12 Alternative Minimum Tax Exemption for a Child Subject to the “Kiddie Tax”

.13 Certain Expenses of Elementary and Secondary School Teachers

.14 Transportation Mainline Pipeline Construction Industry Optional Expense

Substantiation Rules for Payments to Employees Under Accountable Plans

.15 Standard Deduction

.16 Cafeteria Plans

.17 Qualified Transportation Fringe Benefit

.18 Income from United States Savings Bonds for Taxpayers Who

Pay Qualified Higher Education Expenses

.19 Adoption Assistance Programs

.20 Private Activity Bonds Volume Cap

.21 Loan Limits on Agricultural Bonds

.22 General Arbitrage Rebate Rules

.23 Safe Harbor Rules for Broker Commissions on Guaranteed

Investment Contracts or Investments Purchased for a Yield

Restricted Defeasance Escrow

.24 Gross Income Limitation for a Qualifying Relative

.25 Election to Expense Certain Depreciable Assets

.26 Energy Efficient Commercial Buildings Deduction 179D

.27 Qualified Business Income

.28 Eligible Long-Term Care Premiums

.29 Medical Savings Accounts

.30 Interest on Education Loans

.31 Limitation on Use of Cash Method of Accounting

.32 Threshold for Excess Business Loss

.33 Treatment of Dues Paid to Agricultural or Horticultural Organizations

.34 Insubstantial Benefit Limitations for Contributions Associated

With Charitable Fund-Raising Campaigns

.35 Special Rules for Credits and Deductions

November 29, 2021

764

1(j)(2) (A)-(D)

1(g)

1(h)

23

24

32

36B(f)(2)(B)

42(e)

42(h)

45R

55

59(j)

62(a)(2)(D)

62(c)

63

125

132(f)

135

137

146(d)

147(c)(2)

148(f)

148

152(d)(1)(B)

179

199A

213(d)(10)

220

221

448

461(l)

512(d)

513(h)

642

Bulletin No. 2021–48

.36 Tax on Insurance Companies Other than Life Insurance Companies

.37 Expatriation to Avoid Tax

.38 Tax Responsibilities of Expatriation

.39 Foreign Earned Income Exclusion

.40 Debt Instruments Arising Out of Sales or Exchanges

.41 Unified Credit Against Estate Tax

.42 Valuation of Qualified Real Property in Decedent’s Gross Estate

.43 Annual Exclusion for Gifts

.44 Tax on Arrow Shafts

.45 Passenger Air Transportation Excise Tax

.46 Reporting Exception for Certain Exempt Organizations with

Nondeductible Lobbying Expenditures

.47 Notice of Large Gifts Received from Foreign Persons

.48 Persons Against Whom a Federal Tax Lien Is Not Valid

.49 Property Exempt from Levy

.50 Exempt Amount of Wages, Salary, or Other Income

.51 Interest on a Certain Portion of the Estate Tax Payable in Installments

.52 Failure to File Tax Return

.53 Failure to File Certain Information Returns, Registration Statements, etc.

.54 Other Assessable Penalties With Respect to the Preparation of Tax Returns for

Other Persons

.55 Failure to File Partnership Return

.56 Failure to File S Corporation Return

.57 Failure to File Correct Information Returns

.58 Failure to Furnish Correct Payee Statements

.59 Revocation or Denial of Passport in Case of Certain Tax Delinquencies

.60 Attorney Fee Awards

.61 Periodic Payments Received Under Qualified Long-Term Care

Insurance Contracts or Under Certain Life Insurance Contracts Arrangement

.62 Qualified Small Employer Health Reimbursement

831

877

877A

911

1274A

2010

2032A

2503; 2523

4161

4261

6033(e)(3)

6039F

6323

6334(a)

6334(d)

6601(j)

6651

6652

6695

6698

6699

6721

6722

7345

7430

7702B(d)

9831

SECTION 4. EFFECTIVE DATE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 775

SECTION 5. DRAFTING INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 775

SECTION 1. PURPOSE

This revenue procedure sets forth

inflation-adjusted items for 2022 for various provisions of the Internal Revenue

Code of 1986 (Code), as amended, as of

November 9, 2021. To the extent amendments to the Code are enacted for 2022

after November 9, 2021, taxpayers should

consult additional guidance to determine

whether these adjustments remain applicable for 2022.

SECTION 2. CHANGES

.01 For taxable years beginning after

December 31, 2020, Div. EE, Title I,

Subtitle A, §104 of the Consolidated

Appropriations Act, 2021, Pub. L. No.

116-260 (Consolidated Appropriations

Act, 2021) provides that the allowable

Bulletin No. 2021–48

amount of the: (i) American Opportunity

Tax Credit under § 25A(b) of the Code

is phased out for taxpayers with modified adjusted gross income in excess of

$80,000 ($160,000 for joint returns);

and (ii) Lifetime Learning Credit under

§ 25A(c) of the Code is phased out for

taxpayers with modified adjusted gross

income in excess of $80,000 ($160,000

for joint returns). The phaseout range

provided in § 25A(d)(2) is not adjusted

for inflation for taxable years beginning

after December 31, 2020.

.02 For taxable years beginning after

December 31, 2020, Div. EE, Title I,

Subtitle A, §102 of the Consolidated

Appropriations Act, 2021, provides that

the energy efficient commercial buildings deduction is made permanent. In

addition, the amount under § 179D(b)(1)

used to determine the maximum amount

765

of the deductions and the amount under

§ 179D(d)(1)(A) used to determine the

partial allowance amount of the deduction are adjusted for inflation, beginning with taxable years beginning after

December 31, 2020. As a result, for taxable years beginning in 2021, the maximum amount of the deduction allowed

under section 179D(b) is $1.82. For taxable years beginning in 2021, the amount

used to determine the partial allowance

of the deduction under section 179D(d)

(1)(A) is $0.61.

SECTION 3. 2022 ADJUSTED

ITEMS

.01 Tax Rate Tables. For taxable years

beginning in 2022, the tax rate tables

under § 1 are as follows:

November 29, 2021

TABLE 1 - Section 1(j)(2)(A) - Married Individuals Filing Joint Returns and Surviving Spouses

If Taxable Income Is:

The Tax Is:

Not over $20,550

10% of the taxable income

Over $20,550 but

not over $83,550

$2,055 plus 12% of

the excess over $20,550

Over $83,550 but

not over $178,150

$9,615 plus 22% of

the excess over $83,550

Over $178,150 but

not over $340,100

$30,427 plus 24% of

the excess over $178,150

Over $340,100 but

not over $431,900

$69,295 plus 32% of

the excess over $340,100

Over $431,900 but

not over $647,850

$98,671 plus 35% of

the excess over $431,900

Over $647,850

$174,253.50 plus 37% of

the excess over $647,850

TABLE 2 - Section 1(j)(2)(B) – Heads of Households

If Taxable Income Is:

The Tax Is:

Not over $14,650

10% of the taxable income

Over $14,650 but

not over $55,900

$1,465 plus 12% of

the excess over $14,650

Over $55,900 but

not over $89,050

$6,415 plus 22% of

the excess over $55,900

Over $89,050 but

not over $170,050

$13,708 plus 24% of

the excess over $89,050

Over $170,050 but

not over $215,950

$33,148 plus 32% of

the excess over $170,050

Over $215,950 but

not over $539,900

$47,836 plus 35% of

the excess over $215,950

Over $539,900

$161,218.50 plus 37% of

the excess over $539,900

TABLE 3 - Section 1(j)(2)(C) – Unmarried Individuals (other than Surviving Spouses and Heads of Households)

If Taxable Income Is:

The Tax Is:

Not over $10,275

10% of the taxable income

Over $10,275 but

not over $41,775

$1,027.50 plus 12% of

the excess over $10,275

Over $41,775 but

not over $89,075

$4,807.50 plus 22% of

the excess over $41,775

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Bulletin No. 2021–48

Over $89,075 but

not over $170,050

$15,213.50 plus 24% of

the excess over $89,075

Over $170,050 but

not over $215,950

$34,647.50 plus 32% of

the excess over $170,050

Over $215,950 but

not over $539,900

$49,335.50 plus 35% of

the excess over $215,950

Over $539,900

$162,718 plus 37% of

the excess over $539,900

TABLE 4 - Section 1(j)(2)(D) – Married Individuals Filing Separate Returns

If Taxable Income Is:

The Tax Is:

Not over $10,275

10% of the taxable income

Over $10,275 but

not over $41,775

$1,027.50 plus 12% of

the excess over $10,275

Over $41,775 but

not over $89,075

$4,807.50 plus 22% of

the excess over $41,775

Over $89,075 but

not over $170,050

$15,213.50 plus 24% of

the excess over $89,075

Over $170,050 but

not over $215,950

$34,647.50 plus 32% of

the excess over $170,050

Over $215,950 but

not over $323,925

$49,335.50 plus 35% of

the excess over $215,950

Over $323,925

$87,126.75 plus 37% of

the excess over $323,925

TABLE 5 - Section 1(j)(2)(E) – Estates and Trusts

If Taxable Income Is:

The Tax Is:

Not over $2,750

10% of the taxable income

Over $2,750 but

not over $9,850

$275 plus 24% of

the excess over $2,750

Over $9,850 but

not over $13,450

$1,979 plus 35% of

the excess over $9,850

Over $13,450

$3,239 plus 37% of

the excess over $13,450

.02 Unearned Income of Minor Children (the “Kiddie Tax”). For taxable years

beginning in 2022, the amount in § 1(g)(4)

(A)(ii)(I), which is used to reduce the net

unearned income reported on the child’s

return that is subject to the “kiddie tax,”

is $1,150. This $1,150 amount is the same

as the amount provided in § 63(c)(5)(A),

Bulletin No. 2021–48

as adjusted for inflation. The same $1,150

amount is used for purposes of § 1(g)(7)

(that is, to determine whether a parent may

elect to include a child’s gross income in

the parent’s gross income and to calculate

the “kiddie tax”). For example, one of the

requirements for the parental election is

that a child’s gross income is more than

767

the amount referenced in § 1(g)(4)(A)(ii)

(I) but less than 10 times that amount;

thus, a child’s gross income for 2022 must

be more than $1,150 but less than $11,500.

.03 Maximum Capital Gains Rate. For

taxable years beginning in 2022, the Maximum Zero Rate Amount under § 1(h)(1)(B)

(i) is $83,350 in the case of a joint return or

November 29, 2021

surviving spouse ($41,675 in the case of a

married individual filing a separate return),

$55,800 in the case of an individual who

is a head of household (§ 2(b)), $41,675 in

the case of any other individual (other than

an estate or trust), and $2,800 in the case

of an estate or trust. The Maximum 15-percent Rate Amount under § 1(h)(1)(C)(ii)(l)

is $517,200 in the case of a joint return or

surviving spouse ($258,600 in the case of a

married individual filing a separate return),

$488,500 in the case of an individual who is

the head of a household (§ 2(b)), $459,750

in the case of any other individual (other

than an estate or trust), and $13,700 in the

case of an estate or trust.

.04 Adoption Credit. For taxable years

beginning in 2022, under § 23(a)(3) the

credit allowed for an adoption of a child

with special needs is $14,890. For taxable

years beginning in 2022, under § 23(b)

(1) the maximum credit allowed for other

adoptions is the amount of qualified adoption expenses up to $14,890. The available adoption credit begins to phase out

under § 23(b)(2)(A) for taxpayers with

modified adjusted gross income in excess

of $223,410 and is completely phased out

for taxpayers with modified adjusted gross

income of $263,410 or more. See section

3.19 for the adjusted items relating to

adoption assistance programs.

.05 Child Tax Credit. For taxable years

beginning in 2022, the amount used in

§ 24(d)(1)(A) to determine the amount of

credit under § 24 that may be refundable

is $1,500.….

.06 Earned Income Credit.

(1) In general. For taxable years beginning in 2022, the following amounts are

used to determine the earned income

credit under § 32(b). The “earned income

amount” is the amount of earned income

at or above which the maximum amount

Item

Earned Income Amount

Maximum Amount of Credit

Threshold Phaseout Amount (Single, Surviving Spouse, or

Head of Household)

Completed Phaseout Amount (Single, Surviving Spouse, or

Head of Household)

Threshold Phaseout Amount (Married Filing Jointly)

Completed Phaseout Amount (Married Filing Jointly)

The instructions for the Form 1040 series

provide tables showing the amount of the

earned income credit for each type of taxpayer.

(2) Excessive Investment Income.

For taxable years beginning in 2022, the

One

$10,980

$3,733

$20,130

of the earned income credit is allowed.

The “threshold phaseout amount” is the

amount of adjusted gross income (or, if

greater, earned income) above which the

maximum amount of the credit begins

to phase out. The “completed phaseout

amount” is the amount of adjusted gross

income (or, if greater, earned income) at

or above which no credit is allowed. The

threshold phaseout amounts and the completed phaseout amounts shown in the

table below for married taxpayers filing a

joint return include the increase provided

in § 32(b)(2)(B), as adjusted for inflation

for taxable years beginning in 2022. The

threshold phaseout amounts and the completed phaseout amounts shown in the

table below for single, surviving spouse,

or head of household taxpayers also apply

to married taxpayers who are not filing a

joint return and satisfy the special rules for

separated spouses in § 32(d).

Number of Qualifying Children

Two

Three or More

$15,410

$15,410

$6,164

$6,935

$20,130

$20,130

None

$7,320

$560

$9,160

$43,492

$49,399

$53,057

$16,480

$26,260

$49,622

$26,260

$55,529

$26,260

$59,187

$15,290

$22,610

earned income tax credit is not allowed

under § 32(i) if the aggregate amount

of certain investment income exceeds

$10,300.

.07 Refundable Credit for Coverage

Under a Qualified Health Plan. For tax-

able years beginning in 2022, the limitation on tax imposed under § 36B(f)(2)

(B) for excess advance credit payments is

determined using the following table:

If the household income

(expressed as a percent

of poverty line) is:

The limitation amount for

unmarried individuals

(other than surviving

spouses and heads of

household) is:

The limitation amount for

all other taxpayers is:

Less than 200%

At least 200% but less than 300%

At least 300% but less than 400%

$325

$825

$1,400

$650

$1,650

$2,800

November 29, 2021

768

Bulletin No. 2021–48

.08

Rehabilitation

Expenditures

Treated as Separate New Building. For

calendar year 2022, the per low-income

unit qualified basis amount under § 42(e)

(3)(A)(ii)(II) is $7,400.

.09 Low-Income Housing Credit. For

calendar year 2022, the amount used

under § 42(h)(3)(C)(ii) to calculate the

State housing credit ceiling for the low-income housing credit is the greater of (1)

$2.60 multiplied by the State population,

or (2) $2,975,000.

.10 Employee Health Insurance

Expense of Small Employers. For taxable

years beginning in 2022, the dollar amount

in effect under § 45R(d)(3)(B) is $28,700.

This amount is used under § 45R(c) for

limiting the small employer health insurance credit and under § 45R(d)(1)(B)

for determining who is an eligible small

employer for purposes of the credit.

.11 Exemption Amounts for Alternative Minimum Tax. For taxable years beginning in 2022, the exemption amounts under § 55(d)(1)

are:

Joint Returns or Surviving Spouses

Unmarried Individuals (other than Surviving Spouses)

Married Individuals Filing Separate Returns

Estates and Trusts

$118,100

$75,900

$59,050

$26,500

For taxable years beginning in 2022, under § 55(b)(1), the excess taxable income above which the 28 percent tax rate applies is:

Married Individuals Filing Separate Returns

Joint Returns, Unmarried Individuals (other than surviving spouses), and Estates and Trusts

$103,050

$206,100

For taxable years beginning in 2022, the amounts used under § 55(d)(2) to determine the phaseout of the exemption amounts are:

Joint Returns or Surviving Spouses

Unmarried Individuals (other than Surviving Spouses)

Married Individuals Filing Separate Returns

Estates and Trusts

.12 Alternative Minimum Tax Exemption

for a Child Subject to the “Kiddie Tax.” For

taxable years beginning in 2022, for a child

to whom the § 1(g) “kiddie tax” applies,

the exemption amount under §§ 55(d) and

59(j) for purposes of the alternative minimum tax under § 55 may not exceed the

sum of (1) the child’s earned income for the

taxable year, plus (2) $8,200.

.13 Certain Expenses of Elementary

and Secondary School Teachers. For

taxable years beginning in 2022, under

§ 62(a)(2)(D) the amount of the deduction allowed under § 162 that consists of

Threshold Phaseout amount

$1,079,800

$539,900

$539,900

$88,300

expenses paid or incurred by an eligible

educator in connection with books, supplies (other than nonathletic supplies for

courses of instruction in health or physical education), computer equipment

(including related software and services)

and other equipment, and supplementary

materials used by the eligible educator in

the classroom is $300.

.14 Transportation Mainline Pipeline

Construction Industry Optional Expense

Substantiation Rules for Payments to

Employees Under Accountable Plans. For

calendar year 2022, an eligible employer

may pay certain welders and heavy equipment mechanics an amount up to $19

per hour for rig-related expenses that are

deemed substantiated under an accountable plan if paid in accordance with Rev.

Proc. 2002-41, 2002-1 C.B. 1098. If the

employer provides fuel or otherwise reimburses fuel expenses, an amount up to $12

per hour is deemed substantiated if paid

under Rev. Proc. 2002-41.

.15 Standard Deduction.

(1) In general. For taxable years beginning in 2022, the standard deduction

amounts under § 63(c)(2) are as follows:

Filing Status

Married Individuals Filing Joint Returns and Surviving Spouses (§ 1(j)(2)(A))

Heads of Households (§ 1(j)(2)(B))

Unmarried Individuals (other than Surviving Spouses and Heads of Households) (§ 1(j)(2)(C))

Married Individuals Filing Separate Returns (§ 1(j)(2)(D))

Bulletin No. 2021–48

769

Complete Phaseout amount

$1,552,200

$843,500

$776,100

$194,300

Standard Deduction

$25,900

$19,400

$12,950

$12,950

November 29, 2021

(2) Dependent. For taxable years

beginning in 2022, the standard deduction

amount under § 63(c)(5) for an individual who may be claimed as a dependent

by another taxpayer cannot exceed the

greater of (1) $1,150, or (2) the sum of

$400 and the individual’s earned income.

(3) Aged or blind. For taxable years

beginning in 2022, the additional standard

deduction amount under § 63(f) for the

aged or the blind is $1,400. The additional

standard deduction amount is increased to

$1,750 if the individual is also unmarried

and not a surviving spouse.

.16 Cafeteria Plans. For taxable years

beginning in 2022, the dollar limitation

under § 125(i) on voluntary employee salary reductions for contributions to health

flexible spending arrangements is $2,850.

If the cafeteria plan permits the carryover

of unused amounts, the maximum carryover amount is $570.

.17 Qualified Transportation Fringe

Benefit. For taxable years beginning

in 2022, the monthly limitation under

§ 132(f)(2)(A) regarding the aggregate

fringe benefit exclusion amount for transportation in a commuter highway vehicle

and any transit pass is $280. The monthly

limitation under § 132(f)(2)(B) regarding

the fringe benefit exclusion amount for

qualified parking is $280.

.18 Income from United States Savings

Bonds for Taxpayers Who Pay Qualified

Higher Education Expenses. For taxable years beginning in 2022, the exclusion under § 135, regarding income from

United States savings bonds for taxpayers who pay qualified higher education

expenses, begins to phase out for modified

adjusted gross income above $128,650

for joint returns and $85,800 for all other

returns. The exclusion is completely

phased out for modified adjusted gross

income of $158,650 or more for joint

returns and $100,800 or more for all other

returns.

.19 Adoption Assistance Programs.

For taxable years beginning in 2022,

under § 137(a)(2), the amount that can

be excluded from an employee’s gross

income for the adoption of a child with

special needs is $14,890. For taxable years

beginning in 2022, under § 137(b)(1) the

maximum amount that can be excluded

from an employee’s gross income for the

amounts paid or expenses incurred by an

employer for qualified adoption expenses

furnished pursuant to an adoption assistance program for adoptions by the

employee is $14,890. The amount excludable from an employee’s gross income

begins to phase out under § 137(b)(2)

(A) for taxpayers with modified adjusted

gross income in excess of $223,410 and

is completely phased out for taxpayers

with modified adjusted gross income of

$263,410 or more. (See section 3.04 of

this revenue procedure for the adjusted

items relating to the adoption credit.)

.20 Private Activity Bonds Volume

Cap. For calendar year 2022, the amounts

used under § 146(d) to calculate the State

ceiling for the volume cap for private

activity bonds is the greater of (1) $110

multiplied by the State population, or (2)

$335,115,000.

.21 Loan Limits on Agricultural

Bonds. For calendar year 2022, the loan

limit amount on agricultural bonds under

§ 147(c)(2)(A) for first-time farmers is

$575,400.

.22 General Arbitrage Rebate Rules.

For bond years ending in 2022, the amount

of the computation credit determined

under § 1.148-3(d)(4) of the Income Tax

Regulations is $1,830.

.23 Safe Harbor Rules for Broker

Commissions on Guaranteed Investment

Contracts or Investments Purchased for

a Yield Restricted Defeasance Escrow.

For calendar year 2022, under § 1.1485(e)(2)(iii)(B)(1), a broker’s commission

or similar fee for the acquisition of a

Filing Status

Married Individuals Filing Joint Returns

Married Individuals Filing Separate Returns

All Other Returns

November 29, 2021

guaranteed investment contract or investments purchased for a yield restricted

defeasance escrow is reasonable if (1) the

amount of the fee that the issuer treats as

a qualified administrative cost does not

exceed the lesser of (A) $43,000, and (B)

0.2 percent of the computational base (as

defined in § 1.148-5(e)(2)(iii)(B)(2)) or,

if more, $4,000; and (2) for any issue, the

issuer does not treat more than $122,000

in brokers’ commissions or similar fees

as qualified administrative costs for all

guaranteed investment contracts and

investments for yield restricted defeasance escrows purchased with gross proceeds of the issue.

.24 Gross Income Limitation for a

Qualifying Relative. For taxable years

beginning in 2022, the exemption amount

referenced in § 152(d)(1)(B) is $4,400.

.25 Election to Expense Certain Depreciable Assets. For taxable years beginning

in 2022, under § 179(b)(1), the aggregate

cost of any § 179 property that a taxpayer

elects to treat as an expense cannot exceed

$1,080,000 and under § 179(b)(5)(A), the

cost of any sport utility vehicle that may

be taken into account under § 179 cannot exceed $27,000. Under § 179(b)(2),

the $1,080,000 limitation under section

179(b)(1) is reduced (but not below zero)

by the amount by which the cost of § 179

property placed in service during the 2022

taxable year exceeds $2,700,000.

.26 Energy Efficient Commercial Building Deduction. For taxable years beginning in 2022, the maximum amount of the

deduction allowed under section 179D(b)

is $1.88. For taxable years beginning in

2022, the amount used to determine the

partial allowance of the deduction under

section 179D(d)(1)(A) is $0.63.

.27 Qualified Business Income. For taxable years beginning in 2022, the threshold

amounts under § 199A(e)(2) and phase-in

range amounts under § 199A(b)(3)(B) and

§ 199A(d)(3)(A) are:

Threshold amount

$340,100

$170,050

$170,050

770

Phase-in range amount

$440,100

$220,050

$220,050

Bulletin No. 2021–48

.28 Eligible Long-Term Care Premiums. For taxable years beginning in 2022,

the limitations under § 213(d)(10), regarding eligible long-term care premiums

Attained Age Before the Close of the Taxable Year

40 or less

More than 40 but not more than 50

More than 50 but not more than 60

More than 60 but not more than 70

More than 70

.29 Medical Savings Accounts.

(1) Self-only coverage. For taxable

years beginning in 2022, the term “high

deductible health plan” as defined in

§ 220(c)(2)(A) means, for self-only coverage, a health plan that has an annual

deductible that is not less than $2,450 and

not more than $3,700, and under which the

annual out-of-pocket expenses required to

be paid (other than for premiums) for covered benefits do not exceed $4,950.

(2) Family coverage. For taxable

years beginning in 2022, the term “high

deductible health plan” means, for family

coverage, a health plan that has an annual

deductible that is not less than $4,950

and not more than $7,400, and under

which the annual out-of-pocket expenses

required to be paid (other than for premiums) for covered benefits do not exceed

$9,050.

.30 Interest on Education Loans. For

taxable years beginning in 2022, the

$2,500 maximum deduction for interest paid on qualified education loans

under § 221 begins to phase out under

§ 221(b)(2)(B) for taxpayers with modified adjusted gross income in excess of

$70,000 ($145,000 for joint returns), and

is completely phased out for taxpayers

with modified adjusted gross income of

$85,000 or more ($175,000 or more for

joint returns).

.31 Limitation on Use of Cash Method

of Accounting. For taxable years beginning in 2022, a corporation or partnership

meets the gross receipts test of § 448(c)

for any taxable year if the average annual

gross receipts of such entity for the 3-taxable-year period ending with the taxable

year which precedes such taxable year

does not exceed $27,000,000.

.32 Threshold for Excess Business

Loss. For taxable years beginning in 2022,

in determining a taxpayer’s excess busi-

Bulletin No. 2021–48

includible in the term “medical care,” are

as follows:

Limitation on Premiums

$450

$850

$1,690

$4,510

$5,640

ness loss, the amount under § 461(l)(3)

(A)(ii)(II) is $270,000 ($540,000 for joint

returns).

.33 Treatment of Dues Paid to Agricultural or Horticultural Organizations.

For taxable years beginning in 2022, the

limitation under § 512(d)(1), regarding

the exemption of annual dues required to

be paid by a member to an agricultural or

horticultural organization, is $178.

.34 Insubstantial Benefit Limitations

for Contributions Associated with Charitable Fund-Raising Campaigns.

(1) Low cost article. For taxable years

beginning in 2022, for purposes of defining the term “unrelated trade or business”

for certain exempt organizations under

§ 513(h)(2), “low cost articles” are articles

costing $11.70 or less.

(2) Other insubstantial benefits. For

taxable years beginning in 2022, under

§ 170, the $5, $25, and $50 guidelines in

section 3 of Rev. Proc. 90-12, 1990-1 C.B.

471 (as amplified by Rev. Proc. 92-49,

1992-1 C.B. 987, and modified by Rev.

Proc. 92-102, 1992-2 C.B. 579), for the

value of insubstantial benefits that may be

received by a donor in return for a contribution, without causing the contribution

to fail to be fully deductible, are $11.70,

$58.50 and $117, respectively.

.35 Special Rules for Credits and

Deductions. For taxable years beginning

in 2022, the amount of the deduction

under § 642(b)(2)(C)(i) is $4,400.

.36 Tax on Insurance Companies Other

than Life Insurance Companies. For

taxable years beginning in 2022, under

§ 831(b)(2)(A)(i) the amount of the limit

on net written premiums or direct written premiums (whichever is greater) is

$2,450,000 to elect the alternative tax for

certain small companies under § 831(b)

(1) to be taxed only on taxable investment

income.

771

.37 Expatriation to Avoid Tax. For

calendar year 2022, under § 877A(g)(1)

(A), unless an exception under § 877A(g)

(1)(B) applies, an individual is a covered

expatriate if the individual’s “average

annual net income tax” under § 877(a)

(2)(A) for the five taxable years ending

before the expatriation date is more than

$178,000.

.38 Tax Responsibilities of Expatriation. For taxable years beginning in 2022,

the amount that would be includible in

the gross income of a covered expatriate

by reason of § 877A(a)(1) is reduced (but

not below zero) by $767,000 pursuant to

§ 877A(a)(3).

.39 Foreign Earned Income Exclusion.

For taxable years beginning in 2022, the

foreign earned income exclusion amount

under § 911(b)(2)(D)(i) is $112,000.

.40 Debt Instruments Arising Out of

Sales or Exchanges. For calendar year

2022, a qualified debt instrument under

§ 1274A(b) has stated principal that does

not exceed $6,289,500, and a cash method

debt instrument under § 1274A(c)(2)

has stated principal that does not exceed

$4,492,500.

.41 Unified Credit Against Estate Tax.

For an estate of any decedent dying in

calendar year 2022, the basic exclusion

amount is $12,060,000 for determining

the amount of the unified credit against

estate tax under § 2010.

.42 Valuation of Qualified Real Property in Decedent’s Gross Estate. For an

estate of a decedent dying in calendar

year 2022, if the executor elects to use

the special use valuation method under

§ 2032A for qualified real property, the

aggregate decrease in the value of qualified real property resulting from electing

to use § 2032A for purposes of the estate

tax cannot exceed $1,230,000.

.43 Annual Exclusion for Gifts.

November 29, 2021

(1) For calendar year 2022, the first

$16,000 of gifts to any person (other than

gifts of future interests in property) are

not included in the total amount of taxable

gifts under § 2503 made during that year.

(2) For calendar year 2022, the first

$164,000 of gifts to a spouse who is not

a citizen of the United States (other than

gifts of future interests in property) are

not included in the total amount of taxable

gifts under §§ 2503 and 2523(i)(2) made

during that year.

.44 Tax on Arrow Shafts. For calendar year 2022, the tax imposed under

§ 4161(b)(2)(A) on the first sale by the

manufacturer, producer, or importer of

any shaft of a type used in the manufacture of certain arrows is $0.55 per shaft.

.45 Passenger Air Transportation

Excise Tax. For calendar year 2022, the

tax under § 4261(b)(1) on the amount paid

for each domestic segment of taxable air

transportation is $4.50. For calendar year

2022, the tax under § 4261(c)(1) on any

amount paid (whether within or without

the United States) for any international air

transportation, if the transportation begins

or ends in the United States, generally is

$19.70. Under § 4261(c)(3), however, a

lower rate of tax applies under § 4261(c)

(1) to a domestic segment beginning or

ending in Alaska or Hawaii, and the tax

applies only to departures. For calendar

year 2022, the rate of tax is $9.90.

.46 Reporting Exception for Certain

Exempt Organizations with Nondeduct-

ible Lobbying Expenditures. For taxable

years beginning in 2022, the annual per

person, family, or entity dues limitation to

qualify for the reporting exception under

§ 6033(e)(3) (and section 5.05 of Rev.

Proc. 98-19, 1998-1 C.B. 547), regarding

certain exempt organizations with nondeductible lobbying expenditures, is $124 or

less.

.47 Notice of Large Gifts Received from

Foreign Persons. For taxable years beginning in 2022, § 6039F authorizes the Treasury Department and the Internal Revenue

Service to require recipients of gifts from

certain foreign persons to report these gifts

if the aggregate value of gifts received in

the taxable year exceeds $17,339.

.48 Persons Against Whom a Federal

Tax Lien Is Not Valid. For calendar year

2022, a federal tax lien is not valid against

(1) certain purchasers under § 6323(b)

(4) who purchased personal property in

a casual sale for less than $1,690, or (2)

a mechanic’s lien or under § 6323(b)(7)

who repaired or improved certain residential property if the contract price with the

owner is not more than $8,440.

.49 Property Exempt from Levy. For

calendar year 2022, the value of property

exempt from levy under § 6334(a)(2) (fuel,

provisions, furniture, and other household

personal effects, as well as arms for personal use, livestock, and poultry) cannot

exceed $10,090. The value of property

exempt from levy under § 6334(a)(3)

(books and tools necessary for the trade,

Scenario

Organization (§ 6652(c)(1)(A))

Daily Penalty

$20

$110

$10

$20

$20

Maximum Penalty

Lessor of $11,000 or 5%

of gross receipts of the

organization for the year.

$56,000

$5,500

$11,000

No Limit

Daily Penalty

$10

$10

$20

$110

Maximum Penalty

$5,500

$5,500

$11,000

$56,000

Organization with gross receipts exceeding $1,129,000 (§ 6652(c)(1)(A))

Managers (§ 6652(c)(1)(B))

Public inspection of annual returns and reports (§ 6652(c)(1)(C))

Public inspection of applications for exemption and notice of status

(§ 6652(c)(1)(D))

(2) for failure to file a return required

under § 6034 (relating to returns by cer-

tain trust) or § 6043(b) (relating to terminations, etc., of exempt organizations):

Scenario

Organization or trust (§ 6652(c)(2)(A))

Managers (§ 6652(c)(2)(B))

Split-Interest Trust (§ 6652(c)(2)(C)(ii))

Any trust with gross income exceeding $282,000 (§ 6652(c)(2)(C)(ii))

November 29, 2021

business, or profession of the taxpayer)

cannot exceed $5,050.

.50 Exempt Amount of Wages, Salary,

or Other Income. For taxable years beginning in 2022, the dollar amount used to

calculate the amount determined under

§ 6334(d)(4)(B) is $4,400.

.51 Interest on a Certain Portion of the

Estate Tax Payable in Installments. For an

estate of a decedent dying in calendar year

2022, the dollar amount used to determine

the “2-percent portion” (for purposes of

calculating interest under § 6601(j)) of the

estate tax extended as provided in § 6166

is $1,640,000.

.52 Failure to File Tax Return. In the

case of any return required to be filed in

2023, the amount of the addition to tax

under § 6651(a) for failure to file within

60 days of the due date of such return

(determined with regard to any extensions

of time for filing) shall not be less than

the lesser of $450 or 100 percent of the

amount required to be shown as tax on

such return.

.53 Failure to File Certain Information

Returns, Registration Statements, etc. For

returns required to be filed in 2023, the

penalty amounts under § 6652(c) are:

(1) for failure to file a return required

under § 6033(a)(1) (relating to returns

by exempt organization) or § 6012(a)(6)

(relating to returns by political organizations):

772

Bulletin No. 2021–48

(3) for failure to file a disclosure required under § 6033(a)(2):

Scenario

Tax–exempt entity (§ 6652(c)(3)(A))

Failure to comply with written demand (§ 6652(c)(3)(B)(ii))

.54 Other Assessable Penalties With

Respect to the Preparation of Tax Returns

Daily Penalty

$110

$110

for Other Persons. In the case of any failure relating to a return or claim for refund

Scenario

Failure to furnish copy to taxpayer (§ 6695(a))

Failure to sign return (§ 6695(b))

Failure to furnish identifying number (§ 6695(c))

Failure to retain copy or list (§ 6695(d))

Failure to file correct information returns (§ 6695(e))

Negotiation of check (§ 6695(f))

Failure to be diligent in determining eligibility for head of household

filing status, child tax credit, American Opportunity tax credit, and

earned income credit (§ 6695(g))

.55 Failure to File Partnership Return.

In the case of any return required to be

filed in 2023, the dollar amount used to

determine the amount of the penalty under

§ 6698(b)(1) is $220.

.56 Failure to File S Corporation

Return. In the case of any return required

to be filed in 2023, the dollar amount used

to determine the amount of the penalty

under § 6699(b)(1) is $220.

.57 Failure to File Correct Information

Returns. In the case of any failure relating

to a return required to be filed in 2023, the

penalty amounts under § 6721 are:

(1) for persons with average annual

gross receipts for the most recent three

taxable years of more than $5,000,000, for

failure to file correct information returns:

Penalty Per Return

$290

$50

$110

Calendar Year Maximum

$3,532,500

$588,500

$1,766,000

Penalty Per Return

$290

$50

$110

Calendar Year Maximum

$1,177,500

$206,000

$588,500

of the filing requirement (or the correct

information reporting requirement):

Scenario

Return other than a return required to be filed

under §§ 6045(a), 6041A(b), 6050H, 6050I,

6050J, 6050K, or 6050L (§ 6721(e)(2)(A))

Bulletin No. 2021–48

Maximum Penalty

$28,000

$28,000

$28,000

$28,000

$28,000

No limit

No limit

taxable years of $5,000,000 or less, for

failure to file correct information returns:

Scenario

General Rule (§ 6721(d)(1)(A))

Corrected on or before 30 days after required filing date (§ 6721(d)(1)(B))

Corrected after 30th day but on or before August 1, 2023 (§ 6721(d)(1)(C))

(3) for failure to file correct information returns due to intentional disregard

filed in 2023, the penalty amounts under

§ 6695 are:

Per Return or Claim for Refund

$55

$55

$55

$55

$55 per return and item in return

$560 per check

$560 per failure

Scenario

General Rule (§ 6721(a)(1))

Corrected on or before 30 days after required filing date (§ 6721(b)(1))

Corrected after 30th day but on or before August 1, 2023 (§ 6721(b)(2))

(2) for persons with average annual

gross receipts for the most recent three

Maximum Penalty

$56,000

$11,000

Penalty Per Return

Calendar Year Maximum

Greater of (i) $580, or (ii) 10% of aggregate

No limit

amount of items required to be reported correctly

773

November 29, 2021

Scenario

Return required to be filed under §§ 6045(a),

6050K, or 6050L (§ 6721(e)(2)(B))

Return required to be filed under § 6050I(a)

(§ 6721(e)(2)(C))

Return required to be filed under § 6050V

(§ 6721(e)(2)(D))

.58 Failure to Furnish Correct Payee

Statements. In the case of any failure

relating to a statement required to be fur-

Penalty Per Return

Greater of (i) $580, or (ii) 5% of aggregate

amount of items required to be reported correctly

Greater of (i) $29,440, or (ii) amount of cash

received up to $117,500

Greater of (i) $580, or (ii) 10% of the value of

the benefit of any contract with respect to which

information is required to be included on the

return

nished in 2023, the penalty amounts under

§ 6722 are:

(1) for persons with average annual

gross receipts for the most recent three

November 29, 2021

Penalty Per Statement

$290

$50

$110

the requirement to furnish a payee state-

Scenario

Payee statement other than a statement required

under §§ 6045(b), 6041A(e) (in respect of a return

required under § 6041A(b)), 6050H(d), 6050J(e),

6050K(b), or 6050L(c) (§ 6722(e)(2)(A))

Payee statement required under §§ 6045(b),

6050K(b), or 6050L(c) (§ 6722(e)(2)(B))

.59 Revocation or Denial of Passport

in Case of Certain Tax Delinquencies.

For calendar year 2022, the amount of a

serious delinquent tax debt under § 7345

is $55,000.

.60 Attorney Fee Awards. For fees

incurred in calendar year 2022, the attorney fee award limitation under § 7430(c)

(1)(B)(iii) is $220 per hour.

No limit

Calendar Year Maximum

$3,532,500

$588,500

$1,766,000

years of $5,000,000 or less, for failure to

furnish correct payee statements:

Scenario

General Rule (§ 6722(d)(1)(A))

Corrected on or before 30 days after required furnishing date (§ 6722(d)(1)(B))

Corrected after 30th day but on or before August 1, 2023 (§ 6722(d)(1)(C))

(3) for failure to furnish correct payee

statements due to intentional disregard of

No limit

taxable years of more than $5,000,000, for

failure to furnish correct payee statements:

Scenario

Penalty Per Statement

General Rule (§ 6722(a)(1))

$290

Corrected on or before 30 days after required furnishing date (§ 6722(b)(1))

$50

Corrected after 30th day but on or before August 1, 2023 (§ 6722(b)(2))

$110

(2) for persons with average annual

gross receipts for the most recent 3 taxable

Calendar Year Maximum

No limit

Calendar Year Maximum

$1,177,500

$206,000

$588,500

ment (or the correct information reporting

requirement):

Penalty Per Statement

Calendar Year Maximum

Greater of (i) $580, or (ii) 10% of aggregate

No limit

amount of items required to be reported correctly

Greater of (i) $580, or (ii) 5% of aggregate

No limit

amount of items required to be reported correctly

.61 Periodic Payments Received Under

Qualified Long-Term Care Insurance

Contracts or Under Certain Life Insurance Contracts. For calendar year 2022,

the stated dollar amount of the per diem

limitation under § 7702B(d)(4), regarding

periodic payments received under a qualified long-term care insurance contract or

periodic payments received under a life

774

insurance contract that are treated as paid

by reason of the death of a chronically ill

individual, is $390.

.62 Qualified Small Employer Health

Reimbursement Arrangement. For taxable years beginning in 2022, to qualify

as a qualified small employer health reimbursement arrangement under § 9831(d),

the arrangement must provide that the

Bulletin No. 2021–48

total amount of payments and reimbursements for any year cannot exceed $5,450

($11,050 for family coverage).

SECTION 4. EFFECTIVE DATE

.01 General Rule. Except as provided

in section 4.02 of this revenue procedure,

this revenue procedure applies to taxable

years beginning in 2022.

.02 Calendar Year Rule. This revenue procedure applies to transactions or

events occurring in calendar year 2022

for purposes of sections 3.08 (rehabilitation expenditures treated as separate

new building), 3.09 (low-income housing credit), 3.14 (transportation mainline

pipeline construction industry optional

expense substantiation rules for payments

to employees under accountable plans),

3.20 (private activity bonds volume cap),

3.21 (loan limits on agricultural bonds),

3.22 (general arbitrage rebate rules), 3.23

(safe harbor rules for broker commissions on guaranteed investment contracts

or investments purchased for a yield

restricted defeasance escrow), 3.37 (expatriation to avoid taxes), 3.40 (debt instruments arising out of sales or exchanges),

3.41 (unified credit against estate tax),

3.42 (valuation of qualified real property

in decedent’s gross estate), 3.43 (annual

exclusion for gifts), 3.44 (tax on arrow

shafts), 3.45 (passenger air transportation

excise tax), 3.48 (persons against whom a

federal tax lien is not valid), 3.49 (property exempt from levy), 3.51 (interest on a

certain portion of the estate tax payable in

installments), 3.59 (revocation or denial of

passport in case of certain tax delinquencies), 3.60 (attorney fee awards), and 3.61

(periodic payments received under qualified long-term care insurance contracts or

under certain life insurance contracts) of

this revenue procedure.

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue

procedure is William Ruane of the Office

of Associate Chief Counsel (Income Tax

& Accounting). For further information

regarding this revenue procedure, contact

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

Bulletin No. 2021–48

26 CFR 601.105 Examination of returns and claims

for refund, credit or abatement; determination of

correct tax liability.

(Also: Part I, §§ 139, 163, 164, 6041, 6041A,

6050H, 6721, 6722, 6724; §§ 1.6041-1, 1.6050H1(e)(ii), 1.6050H-3(b))

Rev. Proc. 2021-47

SECTION 1. PURPOSE

This revenue procedure addresses the

Federal income tax treatment and information reporting requirements for payments made to or on behalf of financially

distressed individual homeowners by

certain entities with funds allocated from

the Homeowner Assistance Fund (HAF),

which was established under section 3206

of the American Rescue Plan Act of 2021,

Pub. L. No. 117-2, 135 Stat. 4 (March 11,

2021) (ARP), in response to the coronavirus disease (COVID-19) pandemic.

SECTION 2. BACKGROUND

.01 On March 13, 2020, the President

declared that the COVID–19 outbreak in

the United States constituted a national

emergency, beginning March 1, 2020. See

Proclamation 9994, 85 Fed. Reg. 15337

(March 13, 2020). On February 24, 2021,

the President extended the nationwide

emergency due to COVID-19 beyond

March 1, 2021. See Presidential Notice,

86 Fed. Reg. 11599 (February 24, 2021).

.02 As of April 17, 2020, the President

had declared the COVID-19 pandemic a

disaster warranting assistance under the

Robert T. Stafford Disaster Relief and

Emergency Assistance Act, 42 U.S.C. §

5121-5207, in all fifty States, the District

of Columbia, and the United States territories, with an incident date beginning January 20, 2020, and continuing. See Letter

to Federal Agencies on an Emergency

Determination for the Coronavirus Disease 2019 (COVID-19) Pandemic Under

the Robert T. Stafford Disaster Relief and

Emergency Assistance Act, Comp. Pres.

Doc. (Mar. 13, 2020). See for example,

District of Columbia; Major Disaster and

Related Determinations, 85 Fed. Reg.

31534.

.03 In section 3206(a) of the ARP, Congress appropriated funds for fiscal year

2021 that are to remain available until

775

September 30, 2025, to fund the HAF. The

purpose of the HAF is to mitigate financial

hardships associated with the COVID-19

pandemic by providing funds to the eligible entities listed in section 3206(b)

(3) of the ARP for the purpose of paying

certain expenses to prevent: homeowner

mortgage delinquencies; defaults; foreclosures; loss of utilities or home energy

services; and displacements of homeowners experiencing financial hardship after

January 21, 2020.

.04 Section 3206(b)(3) of the ARP provides that eligible entities include: (1) any

State of the United States, the District of

Columbia, the Commonwealth of Puerto

Rico, Guam, American Samoa, the United

States Virgin Islands, and the Commonwealth of the Northern Mariana Islands;

and (2) pursuant to section 3206(f) of the

ARP, entities that are eligible for payments under section 501(b)(2)(A)(i) and

(ii) of subtitle A of title V of division N

of the Consolidated Appropriations Act,

2021 (CAA), Public Law 116–260, 134

Stat. 1182 (December 27, 2020).

.05 Under the HAF program, funds are

appropriated to eligible entities for the

purpose of helping homeowners who satisfy the requirements of section 3206(c)

(2) of the ARP with qualified expenses

related to housing. Section 3206(b)(2) of

the ARP provides a definition of dwelling

which describes the property on which a

homeowner could qualify for payments

from the HAF. Sections 3206(b)(1) and

3206(b)(4) of the ARP define the types of

mortgages on such dwellings that qualify

for payments from the HAF.

.06 Section 3206(c)(1) of the ARP

sets forth a non-exclusive list of qualified expenses, which include: mortgage

payment assistance; financial assistance

to allow a homeowner to reinstate a

mortgage or to pay other housing related

costs related to a period of forbearance,

delinquency, or default; principal reduction; facilitating interest rate reductions;

and payment assistance for: (a) utilities,

including electric, gas, home energy,

and water; (b) internet service, including

broad band internet access service, as

defined in section 8.1(b) of title 47, Code

of Federal Regulations (or any successor

regulation); (c) homeowner’s insurance,

flood insurance, and mortgage insurance;

and (d) homeowner’s association, con-

November 29, 2021

dominium association fees, or common

charges. In addition, section 3206(c)(1)

(G) of the ARP provides that HAF funds

may be used for any other assistance to

promote housing stability for homeowners, including preventing mortgage delinquency, default, foreclosure, post-foreclosure eviction of a homeowner, or the

loss of utility or home energy services, as

determined by the Secretary of the Treasury (Secretary).

.07 Section 61(a) of the Code provides

that, except as otherwise provided by

law, gross income means all income from

whatever source derived.

.08 Section 139(a) of the Code provides that gross income does not include

any amount received by an individual

as a qualified disaster relief payment.

Section 139(b)(4) provides that the term

qualified disaster relief payment includes

any amount paid to or for the benefit of

an individual if such amount is paid by

a Federal, State, or local government, or

agency or instrumentality thereof, in connection with a qualified disaster in order

to promote the general welfare, but only

to the extent any expense compensated

by such payment is not otherwise compensated for by insurance or otherwise.

Section 139(c) defines a qualified disaster, for purposes of § 139(b)(4), to mean

a federally declared disaster within the

meaning of § 165(i)(5)(A) of the Code, or

a disaster which is determined by an applicable Federal, State, or local authority (as

determined by the Secretary) to warrant

assistance from the Federal, State, or local

government, or agency or instrumentality

thereof.

.09 Section 139(h) provides that, notwithstanding any other provision of subtitle A of the Code, no deduction or credit is

allowed (to the person for whose benefit a

qualified disaster relief payment or qualified disaster mitigation payment is made)

for, or by reason of, any expenditure to

the extent of the amount excluded under

§ 139 with respect to such expenditure.

.10 Section 163(h)(2)(D) of the Code

generally allows taxpayers to deduct as

personal interest amounts paid as qualified

residence interest, as defined in § 163(h)

(3), during the taxable year. For this purpose, qualified residence interest generally

includes interest on acquisition indebtedness and certain home equity indebted-

November 29, 2021

ness (subject to certain dollar limitations),

and may include mortgage insurance premiums treated as interest, as defined in

§ 163(h)(3)(E), (collectively, mortgage

interest) with respect to any qualified residence, as defined in § 163(h)(4).

.11 Section 164(a) of the Code generally allows taxpayers to deduct certain taxes paid during the taxable year.

For example, State and local real property taxes are types of taxes that may

be deducted under § 164(a). However,

§ 164(b)(6)(B) provides that, in the case

of an individual, for taxable years beginning after December 31, 2017, and before

January 1, 2026, the aggregate amount of

taxes taken into account under §§ 164(a)

(1), (2), and (3) and 164(b)(5) for any taxable year cannot exceed $10,000 ($5,000

in the case of a married individual filing a

separate return).

.12 Section 3 of this revenue procedure provides an optional safe harbor

method for homeowners to compute their

itemized deductions for mortgage interest and real property taxes when in the

same taxable year the homeowner has

received, or benefited from, a HAF payment from a State, as defined in section

3.02(6) of this revenue procedure, that

may be used to pay a portion of a homeowner’s mortgage interest and/or real

property taxes and the homeowner has

also paid a portion of the mortgage interest and real property taxes with funds

from the Homeowner’s own sources, as

defined in section 3.02(3) of this revenue

procedure. A homeowner is not permitted to deduct under § 163 or § 164, as

applicable, an amount greater than the

amount the homeowner has paid from

the Homeowner’s own sources. Section

4 of this revenue procedure provides

guidance to States, as defined in section

3.02(6) of this revenue procedure, and

mortgage lenders and servicers regarding information reporting requirements

relating to certain HAF payments.

.13 The safe harbor provided in section 3 of this revenue procedure is

similar to the safe harbor provided in

Notice 2018-63, 2018-34 I.R.B. 318, for

the Housing Finance Agency Innovation

Fund for the Hardest Hit Markets (HFA

Hardest Hit Fund), authorized by section

109 of the Emergency Economic Stabilization Act, Division A of Pub. L. 110-343,

776

112 Stat. 3774 (2008). Funding under

HFA Hardest Hit Fund is available for,

but not limited to, programs involving the

following transactions: mortgage modifications; principal forbearance to facilitate

additional mortgage modifications; short

sales and deeds-in-lieu of foreclosure;

unemployment programs; principal reductions for homeowners with severe negative equity; and second-lien reductions

and modifications.

SECTION 3. SAFE HARBOR

METHODS FOR COMPUTING

DEDUCTIONS FOR QUALIFIED

RESIDENCE MORTGAGE

INTEREST AND REAL ESTATE

TAXES

.01 Scope. This revenue procedure

applies to a Homeowner, as defined in section 3.02(2) of this revenue procedure, if:

(1) The Homeowner receives a payment from, or a payment is made on

the Homeowner’s behalf by, a State, as

defined in section 3.02(6) of this revenue

procedure;

(2) The payment is made with funds

from the HAF;

(3) The payment is used to pay qualified expenses, as defined in section 3.02(4)

of this revenue procedure, of the Homeowner, and at least one of the expenses is

a qualified housing payment expense, as

defined in section 3.02(5) of this revenue

procedure;

(4) The Homeowner has also paid a

portion of the qualified housing payment

expense from the Homeowner’s own

sources, as defined in section 3.02(3) of

this revenue procedure;

(5) The Homeowner itemizes deductions on the Homeowner’s Federal income

tax return;

(6) The Homeowner would meet the

requirements of § 163(h)(3) to deduct

qualified mortgage interest expenses,

defined in section 3.02(5)(a) of this revenue procedure, if the Homeowner paid the

qualified mortgage interest expenses from

the Homeowner’s own sources; and

(7) The Homeowner would meet the

requirements of § 164(a)(1) to deduct

qualified real property tax expenses,

defined in section 3.02(5)(b) of this revenue procedure (determined without regard

to § 164(b)(6)(B)), if the Homeowner paid

Bulletin No. 2021–48

the qualified real property tax expenses

from the Homeowner’s own sources.

.02 Definitions.

(1) HAF payment. A HAF payment is

a payment by a State with funds allocated

from the HAF to pay qualified expenses of

a Homeowner.

(2) Homeowner. The term “Homeowner” means an individual homeowner

who satisfies the requirements of section

3206(c)(2) of the ARP and who resides in

a State.

(3) Homeowner’s own sources. Payments are considered to be made from a

Homeowner’s own sources if they are

out-of-pocket payments that are not made

from the HAF or other Federal, State or

local government financial assistance programs.

(4) Qualified expense. The term “qualified expense” has the same meaning as in

section 3206(c)(1) of the ARP. For example, a qualified expense includes, but is not

limited to, mortgage payment assistance;

financial assistance to allow a homeowner

to reinstate a mortgage or to pay other

housing related costs related to a period

of forbearance, delinquency, or default;

principal reduction; facilitating interest

rate reductions; and payment assistance

for: (a) utilities, including electric, gas,

home energy, and water; (b) internet service, including broad band internet access

service, as defined in section 8.1(b) of

title 47, Code of Federal Regulations

(or any successor regulation); (c) homeowner’s insurance, flood insurance, and

mortgage insurance; and (d) homeowner’s

association, condominium association

fees, or common charges.

(5) Qualified housing payment expense.

A qualified housing payment expense

means:

(a) Qualified mortgage interest

expenses, which are qualified residence

interest (defined in § 163(h)(3)) and mortgage insurance premiums treated as interest (defined in § 163(h)(3)(E)) that are

related to a mortgage (defined in section

3206(b)(4) of the ARP) on a qualified residence (defined in § 163(h)(4)) that is a

principal residence; and

(b) Qualified real property tax expenses,

which are State and local (but not foreign)

taxes (within the meaning of § 164(a))

assessed on a principal residence.

Bulletin No. 2021–48

(6) State. The term “State” includes all

fifty states of the United States and the

District of Columbia and any agency or

instrumentality of the foregoing. Unlike

section 3206(b)(7) of the ARP, the term

“State” excludes the Commonwealth of

Puerto Rico, Guam, American Samoa,

the United States Virgin Islands, and the

Commonwealth of the Northern Mariana

Islands.

.03 In general. The COVID-19 pandemic is a qualified disaster within the

meaning of § 139(c). A HAF payment is

a qualified disaster relief payment within

the meaning of § 139(b)(4). As a result,

such payments are not included in the

Homeowner’s gross income. In accordance with § 139(h), a Homeowner that

receives a HAF payment, or on whose

behalf a HAF payment is made, for qualified expenses cannot take a deduction or

credit with respect to such expenses.

.04 Safe harbor methods.

(1) Safe harbor for allocation of HAF

payments. A Homeowner within the scope

of section 3.01 of this revenue procedure

may first allocate the HAF payments to

qualified expenses that are not qualified

housing payment expenses before allocating the remaining portion of the HAF

payments to qualified housing payment

expenses.

(2) Deduction safe harbor. For taxable years beginning on or after January 1, 2021, and before January 1, 2026,

a Homeowner within the scope of section

3.01 of this revenue procedure may use

this safe harbor to calculate the Homeowner’s itemized deduction for qualified mortgage interest expenses and/or

qualified real property tax expenses, as

applicable. The Homeowner may deduct

as qualified mortgage interest expenses

or qualified real property tax expenses

(subject to the limitations in § 163(h)(3)

(E) and § 164(b)(6)(B)) on the Homeowner’s Federal income tax return for

taxable years 2021 through 2025, the

lesser of:

(a) The sum of all payments the Homeowner actually makes from the Homeowner’s own sources during the taxable

year to the mortgage servicer; or

(b) The sum of amounts shown on

Form 1098, Mortgage Interest Statement,

for qualified housing payment expenses.

777

SECTION 4. INFORMATION

REPORTING OBLIGATIONS

.01 Information reporting by States.

(1) Payments to or on behalf of Homeowners - reporting to Homeowners. Section 6041 of the Code requires every person engaged in a trade or business (including the United States or a State, or political subdivision thereof, or the District of

Columbia, or any agency or instrumentality of the foregoing) to file an information

return for each calendar year in which the

person makes in the course of its trade or

business payments to another person of

fixed or determinable income aggregating $600 or more, and to furnish a written

statement to that person. See § 6041(a)

and (d) and § 1.6041-1 of the Income Tax

Regulations. Generally, such payments

are reported on Form 1099‑MISC, Miscellaneous Information. Because HAF payments made to or on behalf of Homeowners are excluded from the gross income

of the Homeowners, they are not fixed or

determinable income under § 6041 and

information reporting for such payments

is not required.

(2) Payments to third parties on behalf

of Homeowners – reporting to third parties.

(a) HAF payments that are made

directly to third parties on behalf of

Homeowners, such as payments made to

insurance companies and homeowners

associations, are generally reportable to

those third parties under § 6041 if they

constitute fixed or determinable income

to the third party and the aggregate payments meet the $600 reporting threshold.

Exceptions to the reporting requirements,

including an exception for payments to

exempt recipients such as corporations,

are provided in § 1.6041-3.

(b) If a State makes a HAF payment to

a service provider on behalf of a Homeowner, such as for essential repairs, that

payment would be reportable under

§ 6041A of the Code. Section 6041A

requires a service-recipient engaged in a

trade or business who pays a person remuneration for services aggregating $600 or

more to file a return reporting such remuneration, and to furnish a written statement to that person. Generally, such payments are reported on Form 1099‑NEC,

November 29, 2021

Nonemployee Compensation. The exceptions set forth in § 1.6041-3 apply. See

Notice 2001-38, 2001-1 I.R.B. 1334 (June

11, 2001).

.02. Information reporting by lender or

mortgage servicer.

(1) Reporting of mortgage interest

received. Section 6050H(a) of the Code

requires every person engaged in a trade

or business to file an information return

for each calendar year in which the person receives in the course of its trade or

business payments from an individual of

interest on a mortgage aggregating $600

or more. Form 1098, Mortgage Interest

Statement, is used for this reporting. Section 6050H(d) further requires that a written statement be furnished to that individual. The regulations provide that interest

received from a governmental unit or an

agency or instrumentality of a governmental unit is not interest received on a mortgage. Section 1.6050H-1(e)(3)(ii). Therefore, lenders who receive a Homeowner’s

mortgage payments directly from a State

should not report the interest received

from the State on Form 1098 as interest

received on the Homeowner’s mortgage.

(2) Reporting mortgage insurance premiums received. Section 6050H(h) and

§ 1.6050H-3 also provide for the reporting of mortgage insurance premiums

November 29, 2021

treated as interest, defined in § 163(h)(3)

(E), received by a person, in the course of

a trade or business, from any individual.

Mortgage insurance premiums treated as

interest aggregating $600 or more for any

calendar year, during periods to which §

163(h)(3)(E) applies, must be reported,

without regard to source. See § 1.6050H3(b). Form 1098 is used for this reporting.

(3) Information Reporting penalties.

Section 6721 of the Code imposes penalties on a person for failing to file an

information return, failing to include

all required information, or including

incorrect information. Section 6722 of

the Code imposes penalties on a person

for failing to furnish a payee statement,

failing to include all required information, or including incorrect information

on a payee statement. Section 6724 of

the Code provides that these penalties

will not be imposed if the failure is due

to reasonable cause and not due to willful

neglect. If a lender files and furnishes a

Form 1098 that includes mortgage interest

received directly from the State, thereby

reporting an incorrect amount of interest

on the information return, the lender will

not be subject to penalties under §§ 6721

and 6722 so long as the lender notifies the

Homeowner that the amounts reported

on the Form 1098 are overstated because

778

they include payments from a governmental unit or an agency or instrumentality

of a governmental unit, and sets forth the

amount of the overstatement. Such notification to the Homeowner should be made

at the time the Form 1098 is furnished or

within 30 days thereafter, and can be provided in a separate statement (written or

electronic), or included on Form 1098 in

Box 10 labeled “Other”.

SECTION 5. EFFECTIVE DATE

This revenue procedure is effective on

November 8, 2021, and applies to qualified expenses paid after January 21, 2020.

SECTION 6. DRAFTING

INFORMATION

The principal authors of this revenue

procedure are Theresa Melchiorre of the

Office of the Associate Chief Counsel

(Income Tax & Accounting) and Nancy

Rose of the Office of the Associate Chief

Counsel (Procedure & Administration).

For further information regarding this revenue procedure, contact Ms. Melchiorre at

(202) 317-4643 (not a toll-free number)

or for questions related to information

reporting, Ms. Rose at (202) (202) 3175147 (not a toll-free number).

Bulletin No. 2021–48

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. 2021–48

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.

November 29, 2021

Numerical Finding List1

Bulletin 2021–48

Announcements:

2021-12, 2021-31 I.R.B. 267

2021-13, 2021-33 I.R.B. 314

2021-14, 2021-33 I.R.B. 315

AOD:

2021-4, 2021-47 I.R.B. 725

Notices:

2021-39, 2021-27 I.R.B. 3

2021-40, 2021-28 I.R.B. 15

2021-41, 2021-29 I.R.B. 17

2021-42, 2021-29 I.R.B. 19

2021-38, 2021-30 I.R.B. 155

2021-44, 2021-31 I.R.B. 166

2021-45, 2021-31 I.R.B. 170

2021-47, 2021-32 I.R.B. 269

2021-46, 2021-33 I.R.B. 303

2021-48, 2021-33 I.R.B. 305

2021-49, 2021-34 I.R.B. 316

2021-43, 2021-35 I.R.B. 332

2021-50, 2021-35 I.R.B. 333

2021-51, 2021-36 I.R.B. 361

2021-52, 2021-38 I.R.B. 381

2021-53, 2021-39 I.R.B. 438

2021-54, 2021-41 I.R.B. 457

2021-55, 2021-41 I.R.B. 461

2021-58, 2021-43 I.R.B. 660

2021-59, 2021-43 I.R.B. 664

2021-57, 2021-44 I.R.B. 706

2021-56, 2021-45 I.R.B. 716

2021-60, 2021-45 I.R.B. 719

2021-35, 2021-46 I.R.B. 723

2021-61, 2021-47 I.R.B. 738

Revenue Procedures:—Continued

2021-34, 2021-35 I.R.B. 337

2021-35, 2021-35 I.R.B. 355

2021-36, 2021-35 I.R.B. 357

2021-37, 2021-38 I.R.B. 385

2021-38, 2021-38 I.R.B. 425

2021-39, 2021-38 I.R.B. 426

2021-40, 2021-38 I.R.B. 426

2021-41, 2021-39 I.R.B. 443

2021-32, 2021-42 I.R.B. 465

2021-44, 2021-42 I.R.B. 469

2021-42, 2021-43 I.R.B. 666

2021-46, 2021-47 I.R.B. 740

2021-45, 2021-48 I.R.B. 764

2021-47, 2021-48 I.R.B. 775

Revenue Rulings:

2021-12, 2021-27 I.R.B. 1

2021-13, 2021-30 I.R.B. 152

2021-14, 2021-31 I.R.B. 164

2021-19, 2021-42 I.R.B. 470

2021-15, 2021-35 I.R.B. 331

2021-16, 2021-36 I.R.B. 359

2021-17, 2021-37 I.R.B. 362

2021-18, 2021-40 I.R.B. 447

2021-21, 2021-44 I.R.B. 704

2021-22, 2021-47 I.R.B. 726

Treasury Decisions:

9951, 2021-30 I.R.B. 25

9952, 2021-39 I.R.B. 428

9953, 2021-39 I.R.B. 430

9956, 2021-41 I.R.B. 449

9957, 2021-41 I.R.B. 452

9955, 2021-42 I.R.B. 471

Proposed Regulations:

REG-107705-21, 2021-30 I.R.B. 162

REG-102951-16, 2021-32 I.R.B. 272

REG-109077-21, 2021-39 I.R.B. 445

REG-100718-21, 2021-42 I.R.B. 653

REG-107707-21, 2021-42 I.R.B. 657

Revenue Procedures:

2021-28, 2021-27 I.R.B. 5

2021-29, 2021-27 I.R.B. 12

2021-24, 2021-29 I.R.B. 19

2021-14, 2021-30 I.R.B. 158

2021-30, 2021-31 I.R.B. 172

2021-31, 2021-33 I.R.B. 324

2021-33, 2021-34 I.R.B. 327

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

November 29, 2021

ii

Bulletin No. 2021–48

Finding List of Current Actions on

Previously Published Items1

Bulletin 2021–48

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. 2021–48

iii

November 29, 2021

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

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

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