These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE

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

Announcement 2022-8, page 1056.

This Announcement is being issued to provide notification to all consumers of the Internal Revenue Bulletin,

that there were no articles submitted for publication in

IRB 2022-19, dated Monday, May 9, 2022.

Finding Lists begin on page ii.





Bulletin No. 2022–19

May 9, 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 Unpublished rulings will not be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.

May 9, 2022 

Bulletin No. 2022–19

Part IV

Announcement 2022-8

This Announcement is being issued to

provide notification to all consumers of

the Internal Revenue Bulletin, that there

were no articles submitted for publication

in IRB 2022-19, dated Monday, May 9,

2022.

May 9, 2022

1056

Bulletin No. 2022–19

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. 2022–19

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.

May 9, 2022

Numerical Finding List1

Bulletin 2022–18

Announcements:

2022-3, 2022-8 I.R.B. 788

2022-4, 2022-9 I.R.B. 789

2022-5, 2022-11 I.R.B. 825

2022-6, 2022-13 I.R.B. 934

2022-7, 2022-15 I.R.B. 946

2022-8, 2022-19 I.R.B. 1056

AOD:

2022-1, 2022-06 I.R.B. 466

2022-2, 2022-12 I.R.B. 903

Notices:

2022-1, 2022-02 I.R.B. 304

2022-2, 2022-02 I.R.B. 304

2022-3, 2022-02 I.R.B. 308

2022-4, 2022-02 I.R.B. 309

2022-5, 2022-05 I.R.B. 457

2022-6, 2022-05 I.R.B. 460

2022-7, 2022-06 I.R.B. 469

2022-8, 2022-07 I.R.B. 491

2022-9, 2022-10 I.R.B. 811

2022-10, 2022-10 I.R.B. 815

2022-12, 2022-12 I.R.B. 906

2022-11, 2022-14 I.R.B. 939

2022-13, 2022-14 I.R.B. 940

2022-14, 2022-14 I.R.B. 941

2022-15, 2022-18 I.R.B. 1043

2022-16, 2022-18 I.R.B. 1044

2022-17, 2022-18 I.R.B. 1048

2022-18, 2022-18 I.R.B. 1048

2022-19, 2022-18 I.R.B. 1050

Revenue Procedures:—Continued

2022-13, 2022-06 I.R.B. 477

2022-12, 2022-07 I.R.B. 494

2022-14, 2022-07 I.R.B. 502

2022-15, 2022-13 I.R.B. 908

2022-17, 2022-13 I.R.B. 930

2022-17, 2022-13 I.R.B. 933

2022-20, 2022-14 I.R.B. 945

2022-21, 2022-16 I.R.B. 1015

2022-23, 2022-18 I.R.B. 1052

Revenue Rulings:

2022-1, 2022-02 I.R.B. 301

2022-2, 2022-04 I.R.B. 451

2022-3, 2022-06 I.R.B. 467

2022-4, 2022-10 I.R.B. 790

2022-5, 2022-10 I.R.B. 792

2022-6, 2022-12 I.R.B. 904

2022-7, 2022-14 I.R.B. 935

2022-8, 2022-14 I.R.B. 936

2022-9, 2022-18 I.R.B. 1041

Treasury Decisions:

9959, 2022-03 I.R.B. 328

9961, 2022-03 I.R.B. 430

9960, 2022-07 I.R.B. 481

9962, 2022-11 I.R.B. 823

Proposed Regulations:

REG-118250-20, 2022-07 I.R.B. 753

REG-105954-20, 2022-11 I.R.B. 828

REG-114209-21, 2022-11 I.R.B. 898

REG-114209-21, 2022-11 I.R.B. 898

REG-121508-18, 2022-15 I.R.B. 996

REG-114339-21, 2022-17 I.R.B. 1030

Revenue Procedures:

2022-1, 2022-01 I.R.B. 1

2022-2, 2022-01 I.R.B. 120

2022-3, 2022-01 I.R.B. 144

2022-4, 2022-01 I.R.B. 161

2022-5, 2022-01 I.R.B. 256

2022-7, 2022-01 I.R.B. 297

2022-9, 2022-02 I.R.B. 310

2022-11, 2022-03 I.R.B. 449

2022-8, 2022-04 I.R.B. 451

2022-10, 2022-06 I.R.B. 473

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2021.

1

May 9, 2022

ii

Bulletin No. 2022–19

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–18

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2021.

1

Bulletin No. 2022–19

iii

May 9, 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/.

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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

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