Bulletin No. 2022–14

Agency decision

Ask Donna

What actually matters in this document.

Text

HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2022–14

April 4, 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

EMPLOYEE PLANS

Rev. Proc. 2022-20, page 945.

This revenue procedure provides guidance regarding

the public approval requirement under § 147(f) of the

Internal Revenue Code for tax-exempt qualified private

activity bonds. Specifically, this revenue procedure provides that hearings held by teleconference as described

in section 4 of this revenue procedure will be treated as

held in a location that, based on the facts and circumstances, is convenient for residents of the approving

governmental unit for the purpose of § 1.147(f)-1(d)(2)

of the Income Tax Regulations.

Notice 2022-14, page 941.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment

rates for March 2022 used under § 417(e)(3)(D), the

24-month average segment rates applicable for March

2022, and the 30-year Treasury rates, as reflected by

the application of § 430(h)(2)(C)(iv).

Rev. Rul. 2022-7, page 935.

This ruling updates Rev. Rul. 2004-53 in accordance

with the Taxpayer First Act by explaining that all recipients of returns or return information pursuant to section

6103(c), including government employees, are subject

to the disclosure restrictions of section 6103(a). Rev.

Rul. 2004-53 modified and superseded.

ADMINISTRATIVE; INCOME TAX

Notice 2022-13, page 940.

Notice 2022-13 provides a waiver of the addition to

tax under section 6654 for underpayment of estimated income tax by qualifying farmers and fishermen described in the notice. Under the notice, the addition to

tax is waived for farmers and fishermen who, by April

18, 2022, or, for those taxpayers who reside in Maine

or Massachusetts, by April 19, 2022, file their 2021

federal income tax return and pay in full any tax reported as due on the return.

Finding Lists begin on page ii.

EXCISE TAX

Notice 2022-11, page 939.

The notice provides an indexing factor for the qualifying

payment amount for items and services furnished in

2022 for purposes of sections 9816 and 9817 of the

Internal Revenue Code, as added by the No Surprise

Act, in the case of a group health plan or group or individual health insurance issuer that does not have sufficient information as of January 31, 2019 to calculate

the median of the contracted rates or for new items

and services.

INCOME TAX

Rev. Rul. 2022-8, page 936.

Federal rates; adjusted federal rates; adjusted federal

long-term rate, and the long-term tax exempt rate. For

purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for

April 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.

April 4, 2022

Bulletin No. 2022–14

Part I

Section 6103.—

Confidentiality and

disclosure of returns and

return information

26 CFR 301.6103: Confidentiality of returns.

Rev. Rul. 2022-7

ISSUE

Whether Federal, State, and local government officers or employees (government employees) are subject to the disclosure restrictions of section 6103(a) of

the Internal Revenue Code (Code) with

regard to returns or return information received as a result of disclosure under:

• section 6103(c) with the consent

of the taxpayer (taxpayer consent

exception),

• section 6103(e) as a person having a

material interest, but not under section 6103(e)(1)(D)(iii) relating to

disclosures to certain shareholders

(material interest exception), or

• section 6103(k)(6) for investigative

purposes (investigative disclosure

exception).

FACTS

Situation 1. A requests the assistance

of a friend, B, with respect to a Federal

tax matter. A also requests that the Internal Revenue Service (IRS) provide A’s

returns and return information to B. B

subsequently discloses to a third party return information obtained as a result of A’s

request.

Situation 2. Same as Situation 1, above,

except that B happens to be an employee

in the office of a State agency.

Situation 3. C is an attorney employed

by a law firm. The firm has a policy of taking disciplinary action against any of its

attorneys who do not properly fulfill their

tax obligations. The IRS serves a notice

of levy with respect to C’s tax liability on

the payroll department of the firm. D is a

payroll department employee of the firm.

D processes the notice of levy and informs

Bulletin No. 2022–14

the firm’s managing partners of C’s tax delinquency to enable the firm to take appropriate action consistent with firm policy.

Situation 4. E is an employee of a State

agency. The agency has a policy of taking disciplinary action against employees

who do not properly fulfill their tax obligations. The IRS serves a notice of levy

with respect to E’s tax liability on the payroll department of the State agency. F is a

payroll department employee of the State

agency. F processes the notice of levy and

informs the appropriate office of the State

agency of E’s tax delinquency to enable

the agency to take appropriate action consistent with agency policy.

Situation 5. Same as Situation 4, above,

except that E and F are employees of a

Federal agency.

Situation 6. G is the father of 5-year-old

film star H. H’s mother signs H’s return as

parent for a minor child and dies shortly

thereafter. G is the guardian of H’s estate

under applicable State law. G receives notice that H’s return is under examination

by the IRS. G does not have a copy of H’s

return, so G obtains the return and return

information from the IRS. When subsequently asked by a news reporter how

much income H reported on the return, G

replies “three million dollars.”

Situation 7. Same as Situation 6, above,

except that G happens to be an employee

of a Federal agency.

LAW

Generally, section 6103 provides that

returns (as defined in section 6103(b)(1))

and return information (as defined in section 6103(b)(2)) are confidential and may

not be disclosed except as expressly authorized by the Code. Specifically, “except as

authorized by this title” (that is, the Code),

section 6103(a) prohibits the disclosure

by officers or employees of the United

States, of any State, or of specified local

government agencies, or by certain other

specified persons, of returns and return

information obtained in connection with

their service as such an officer or employee or otherwise or under the provisions of

section 6103 (disclosure restrictions). See

Girard v. Bentsen, 94-2 U.S.T.C. ¶ 50,625

935

(N.D. Cal. 1994) (“or otherwise” modifies

“in connection with his service,” allowing

the statute to cover those who are neither “officers” nor “employees,” namely

certain other persons specified in section

6103(a)). For purposes of section 6103(a),

the term “officer or employee” includes a

former officer or employee.

There are, however, exceptions to the

general rule of confidentiality. First, the

taxpayer consent exception permits the

disclosure of returns and return information to a designee of the taxpayer, pursuant to the taxpayer’s request or consent. To be valid, a consent must satisfy

the requirements of section 6103(c) and

§ 301.6103(c)-1 of the Procedure and Administration Regulations. Second, the material interest exception permits the disclosure of returns and return information

to specific persons with a material interest

in the information. Third, the investigative disclosure exception, in conjunction

with § 301.6103(k)(6)-1, authorizes the

disclosure of return information (but not

returns) to the extent that disclosure is

necessary in obtaining information that is

not otherwise reasonably available with

respect to the correct determination of tax,

liability for tax, or the amount to be collected, or with respect to the enforcement

of any other provision of the Code.

Rev. Rul. 2004-53, 2004-1 C.B. 1026

(June 7, 2004) clarified the scope of section 6103(a) with respect to government

employees and held that government employees who receive returns or return information pursuant to section 6103(c), (e),

or (k)(6) are not subject to the disclosure

restrictions of section 6103(a). Although

not addressed by Rev. Rul. 2004-53, any

shareholder of a corporation permitted to

inspect or receive return information of

the corporation or its subsidiaries under

section 6103(e)(1)(D)(iii) is subject to the

disclosure restrictions imposed by section

6103(a).

Section 2202 of the Taxpayer First Act

(TFA), Public Law 116-25, 133 Stat. 981,

1012 (2019), amended section 6103(a)

(3) and (c) to limit redisclosures and uses

of return information received pursuant

to the taxpayer consent exception. Section 6103(c), as amended by the TFA,

April 4, 2022

explicitly prohibits designees from using

return information for any reason other

than the express purpose for which the

taxpayer grants consent and from redisclosing return information without the

taxpayer’s express permission or request.

Section 6103(a)(3), as amended by the

TFA, imposes disclosure restrictions on

all recipients of return information under

6103(c). The TFA did not amend section 6103(e) or (k)(6), or section 6103(a)

with respect to disclosures under section

6103(e) or (k)(6).

ANALYSIS

Under section 6103(c), as amended,

the restrictions on redisclosure of returns

or return information received pursuant to

the taxpayer consent exception apply to all

designees, including government employees. Therefore, in Situations 1 and 2, B is

prohibited from redisclosing A’s return information, because A did not authorize B

to further disclose A’s return information.

After the TFA, the analysis of the scope

of disclosures under section 6103(e) and

(k)(6) is materially unchanged from that

in Rev. Rul. 2004-53. Section 6103(e) and

(k)(6) contains no limitation or restriction

on the redisclosure of returns or return

information received pursuant to the material interest or investigative disclosure

exceptions. Therefore, in Situations 3 and

6 there are no statutory or regulatory restrictions on the redisclosures of return

information made by D or G.

In Situations 4, 5, and 7, however, the

prohibition in section 6103(a) on redisclosure of returns or return information by

government employees could be read to

prohibit such redisclosures by F and G because they happen to be government employees. This reading would create a disparity in the application of section 6103(a)

based on who the employer of the person

receiving the disclosure of returns or return information happens to be.

By its terms, section 6103(a) does not

regulate or control the use of returns and

return information received under the material interest or investigative disclosure

exceptions. Moreover, the requirements

for accountings and safeguards that typically apply where redisclosure of returns

or return information is limited do not apply to these exceptions.

April 4, 2022

There is no evidence that Congress

intended to limit the redisclosure of return information received by government

employees under section 6103(e) and

(k)(6) merely because they happen to

be government employees. On the contrary, there are compelling reasons for

those government employees to be subject to the same rules as other recipients.

For example, a private sector employer

may take disciplinary action against employees who do not properly fulfill their

tax obligations. If redisclosure of return

information is not permitted because

the employer happens to be the Federal government, the Federal employees

who failed to fulfill their tax obligations

would be in a significantly better position

than their private sector counterparts.

This inappropriate result only occurs if

section 6103(a) is read to apply to individuals merely because they happen to be

government employees.

Accordingly, persons are not barred

because of their status as government

employees from redisclosing returns and

return information received pursuant to

section 6103(e) or (k)(6). Therefore, in

Situations 4, 5, and 7, there are no statutory or regulatory restrictions on the redisclosures of return information made by

F or G.

HOLDING

Government employees who receive

returns or return information pursuant to

disclosures under section 6103(c), like

all designees who receive returns or return information pursuant to taxpayer

consent, are subject to the disclosure restrictions of section 6103(a). Government

employees who receive returns or return

information pursuant to disclosures under section 6103(k)(6) or (e), other than

section 6103(e)(1)(D)(iii) (relating to certain shareholders), are not subject to the

disclosure restrictions of section 6103(a)

with regard to the returns or return information received.

EFFECT ON OTHER REVENUE

RULINGS

DRAFTING INFORMATION

The principal author of this revenue

ruling is Andrew C. Keaton of the Office

of the Associate Chief Counsel (Procedure

& Administration). For further information regarding this revenue ruling, contact

Mr. Keaton at (202) 317-5404 (not a tollfree number).

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2022-8

This revenue ruling provides various prescribed rates for federal income

tax purposes for April 2022 (the current

month). Table 1 contains the short-term,

mid-term, and long-term applicable federal rates (AFR) for the current month for

purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the

short-term, mid-term, and long-term adjusted applicable federal rates (adjusted

AFR) for the current month for purposes

of section 1288(b). Table 3 sets forth the

adjusted federal long-term rate and the

long-term tax-exempt rate described in

section 382(f). Table 4 contains the appropriate percentages for determining the

low-income housing credit described in

section 42(b)(1) for buildings placed in

service during the current month. However, under section 42(b)(2), the applicable

percentage for non-federally subsidized

new buildings placed in service after July

30, 2008, shall not be less than 9%. Finally, Table 5 contains the federal rate for determining the present value of an annuity,

an interest for life or for a term of years, or

a remainder or a reversionary interest for

purposes of section 7520.

Rev. Rul. 2004-53 is modified and

superseded.

936

Bulletin No. 2022–14

Annual

AFR

110% AFR

120% AFR

130% AFR

1.26%

1.39%

1.52%

1.65%

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

1.87%

2.06%

2.24%

2.43%

2.81%

3.29%

AFR

110% AFR

120% AFR

130% AFR

2.25%

2.48%

2.71%

2.93%

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

REV. RUL. 2022-8 TABLE 1

Applicable Federal Rates (AFR) for April 2022

Period for Compounding

Semiannual

Quarterly

Short-term

1.26%

1.39%

1.51%

1.64%

Mid-term

1.86%

2.05%

2.04%

2.23%

2.22%

2.42%

2.41%

2.79%

2.78%

3.26%

3.25%

Long-term

2.24%

2.23%

2.46%

2.45%

2.69%

2.68%

2.91%

2.90%

Annual

0.96%

1.41%

1.71%

REV. RUL. 2022-8 TABLE 2

Adjusted AFR for April 2022

Period for Compounding

Semiannual

0.96%

1.41%

1.70%

Quarterly

0.96%

1.41%

1.70%

REV. RUL. 2022-8 TABLE 3

Rates Under Section 382 for April 2022

Adjusted federal long-term rate for the current month

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal

long-term rates for the current month and the prior two months.)

Monthly

1.26%

1.39%

1.51%

1.63%

1.85%

2.04%

2.22%

2.41%

2.77%

3.24%

2.23%

2.45%

2.68%

2.89%

Monthly

0.96%

1.41%

1.69%

1.71%

REV. RUL. 2022-8 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for April 2022

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July

30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit

7.47%

Appropriate percentage for the 30% present value low-income housing credit

3.20%

Bulletin No. 2022–14

937

April 4, 2022

REV. RUL. 2022-8 TABLE 5

Rate Under Section 7520 for April 2022

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a

remainder or reversionary interest

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8 page 936.

Section 382.—Limitation

on Net Operating Loss

Carryforwards and

Certain Built-In Losses

Following Ownership

Change

The adjusted applicable federal long-term rate

is set forth for the month of April 2022. See Rev.

Rul. 2022-8, page 936.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of April 2022. See Rev. Rul.

2022-8, page 936.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

2.2%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

Section 1288.—Treatment

of Original Issue Discount

on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of April 2022. See Rev. Rul.

2022-8, page 936.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2022. See Rev. Rul. 2022-8, page 936.

April 4, 2022

938

Bulletin No. 2022–14

Part III

26 CFR 54.9816-6T Methodology for calculating

qualifying payment amount in 2022

NOTICE 2022-11

SECTION 1. PURPOSE AND SCOPE

This notice provides guidance for calculating the qualifying payment amount

for items and services furnished in 2022

for purposes of sections 9816 and 9817 of

the Internal Revenue Code (Code), sections 716 and 717 of the Employee Retirement Income Security Act of 1974 (ERISA), and sections 2799A-1 and 2799A-2

of the Public Health Service Act (PHS

Act) in the case of a group health plan

or group or individual health insurance

issuer that does not have sufficient information to calculate the median of the contracted rates in 2019 (including for items

and services not offered in 2019). This

notice was drafted in consultation with

the Departments of Labor and Health and

Human Services.

SECTION 2. BACKGROUND

Under Treas. Reg. § 54.9816-6T(c),

29 CFR 2590.716-6(c), and 45 CFR

149.140(c),1 for an item or service furnished during 2022, a group health plan

or group or individual health insurance

issuer2 must calculate the qualifying payment amount by increasing the median

contracted rate (as determined in accordance with § 54.9816-6T(b), 29 CFR

2590.716-6(b), and 45 CFR 149.140(b))

for the same or similar item or service

under such plan or coverage, on January

31, 2019, by the combined percentage

increase as published by the Department

of the Treasury (Treasury Department)

and the Internal Revenue Service (IRS)

to reflect the percentage increase in the

consumer price index for all urban consumers (U.S. city average) (CPI-U) over

2019, such percentage increase over 2020,

and such percentage increase over 2021.

Per Rev. Proc. 2022-11, 2022-3 IRB 449,

for items and services provided on or after January 1, 2022, and before January 1,

2023, the combined percentage increase

to adjust the median contracted rate is

1.0648523983.

Pursuant to § 54.9816-6T(c)(3)(i), 29

CFR 2590.716-6(c)(3)(i), and 45 CFR

149.140(c)(3)(i), for an item or service

furnished during 2022, a plan or issuer

that does not have sufficient information

to calculate the median of the contracted

rates in 2019 for the same or similar item

or service provided in a geographic region

must calculate the qualifying payment

amount by first identifying the rate that

is equal to the median of the in-network

allowed amounts for the same or similar

item or service provided in the geographic

region in 2021, determined by the plan or

issuer through use of any eligible database,

and then increasing that rate by the percentage increase in the CPI-U over 2021.

Similarly, in the case of a newly covered

item or service furnished during the first

coverage year, when a plan or issuer does

not have sufficient information to calculate the median of the contracted rates in

the first coverage year for the item or service, the plan or issuer must calculate the

qualifying payment amount by using an

eligible database to determine the rate that

is equal to the median of the in-network

allowed amounts for the same or similar

item or service provided in the geographic

region in the year immediately preceding

the first coverage year, and then increasing

that rate by the percentage increase in the

CPI-U over the preceding year.3

Under § 54.9816-6T(c)(3)(ii), 29

CFR 2590.716-6(c)(3)(ii), and 45 CFR

149.140(c)(3)(ii), for an item or service

furnished in a subsequent year (before

the first sufficient information year for the

item or service with respect to the plan or

coverage), the plan or issuer must calculate the qualifying payment amount by

increasing the qualifying payment amount

determined for the item or service for the

year immediately preceding the subsequent year, by the percentage increase in

the CPI-U over the preceding year.

SECTION 3. GUIDANCE

The percentage increase in the CPI-U

over a preceding year is calculated by

dividing the average CPI-U for the preceding year by the average CPI-U for the

year immediately prior to the preceding

year. For this purpose, the average CPI-U

for a year is the average of the monthly

CPI-Us published by the Bureau of Labor

Statistics of the Department of Labor for

the 12-month period ending on August 31

of each year. The percentage increase in

the CPI-U for items and services provided in 2022 over the preceding year is the

average CPI-U for 2021 over the average

CPI-U for 2020. Pursuant to this calculation, the percentage increase from 2021 to

2022 is 1.0299772040.

Therefore, for an item or service furnished in 2022 for which a plan or issuer does not have sufficient information

to calculate the median of the contracted

rates in 2019, the plan or issuer must calculate the qualifying payment amount by

multiplying the median of the in-network

allowed amounts for the same or similar

item or service provided in the geographic

region in 2021, drawn from any eligible

database, by the percentage increase of

1.0299772040. Similarly, in the case of a

newly covered item or service furnished

in 2022, when 2022 is the first coverage

year for the item or service with respect

to the plan or coverage, the plan or issuer must calculate the qualifying payment

amount by multiplying the median of the

in-network allowed amounts for the same

or similar item or service provided in the

geographic region in 2021, drawn from

any eligible database, by the percentage

increase of 1.0299772040. Pursuant to

These interim final rules were issued in July 2021 to implement sections 9816 and 9817 of the Code, sections 716 and 717 of ERISA, and sections 2799A-1 and 2799A-2 of the PHS Act.

86 FR 36872 (7/13/21).

5 CFR 890.114(b) provides that, for purposes of the No Surprises Act, “group health plan” means “a health benefits plan” offered by carriers under the Federal Employees Health Benefits

(FEHB) Act. Accordingly, the guidance provided in this notice also applies to FEHB carriers. See 5 U.S.C. 8901(p).

In cases in which an eligible database is used to determine the qualifying payment amount with respect to an item or service furnished during a calendar year, the plan or issuer must use the

same database for determining the qualifying payment amount for that item or service through the last day of the calendar year, and if a different database is selected for some items or services,

the basis for that selection must be one or more factors not directly related to the rate of those items or services (such as sufficiency of data for those items or services).

Bulletin No. 2022–14

939

April 4, 2022

this notice, plans and issuers may round

any resulting qualifying payment amount

to the nearest dollar.

The Treasury Department and the IRS

anticipate issuing additional guidance regarding the calculation of the qualifying

payment amount in these circumstances

for subsequent years.

SECTION 4. EFFECTIVE DATE

The effective date of this notice is January 1, 2022.

SECTION 5. DRAFTING

INFORMATION

The principal author of this notice is

Kari DiCecco of the Office of Associate

Chief Counsel (Employee Benefits, Exempt Organizations, and Employment

Taxes). For further information regarding

this notice, contact Kari DiCecco at 202317-5500 (not a toll-free number).

Relief from Addition to

Tax for Underpayment of

Estimated Income Tax by

Individual Farmers and

Fishermen

Notice 2022-13

SECTION 1. PURPOSE

This notice provides a waiver of the

addition to tax under section 6654 of the

Internal Revenue Code (Code) for underpayment of estimated income tax by qualifying farmers and fishermen described in

this notice.

SECTION 2. BACKGROUND

Generally, the Code requires taxpayers

to pay federal income taxes as they earn

income. To the extent these taxes are not

withheld from wages or other sources, a

taxpayer must pay estimated income tax

on a quarterly basis.

Section 6654 provides that, in the

case of an individual taxpayer, estimated income tax is required to be paid in

April 4, 2022

four installments, each of which is 25

percent of the required annual payment.

With some exceptions, section 6654(l)

(2) provides that the provisions of section

6654 generally apply to certain trusts and

estates.

An individual taxpayer who fails to

make a sufficient and timely payment

of estimated income tax generally is liable for an addition to tax under section

6654(a). However, special rules may apply in the case of an individual taxpayer

who is a farmer or fisherman and satisfies

the requirements of section 6654(i) for a

taxable year (qualifying farmer or fisherman). Under section 6654(i)(1), a qualifying farmer or fisherman has only one

required installment payment instead of

four quarterly payments due on January

15 of the year following the taxable year

if at least two-thirds of the taxpayer’s total

gross income was from farming or fishing

in either the taxable year or the preceding

taxable year. For a qualifying farmer or

fisherman who does not make the required

estimated tax installment payment by January 15 of the year following the taxable

year, section 6654(i)(1)(D) provides that

the taxpayer is not subject to an addition

to tax for failing to pay estimated income

tax if the taxpayer files the return for the

taxable year and pays the full amount of

tax reported on the return by March 1 of

the year following the taxable year.

The Secretary of the Treasury or her

delegate is authorized under section

6654(e)(3)(A) to waive the section 6654

addition to tax for an underpayment of

estimated tax in unusual circumstances to

the extent its imposition would be against

equity and good conscience.

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) understand that, for

the 2021 taxable year, some qualifying

farmers and fishermen have been unable

to electronically file Form 7203, S Corporation Shareholder Stock and Debt Basis

Limitations, which may be required to be

included in their federal income tax returns for taxable year 2021 (2021 tax returns). Due to this inability, farmers and

fishermen may have had difficulty filing

their 2021 tax returns electronically by the

March 1, 2022, due date provided by section 6654(i)(1). Accordingly, the Treasury

Department and the IRS have determined

940

it is appropriate to waive certain penalties

for qualifying farmers and fishermen due

to these unusual circumstances if the requirements set forth in section 3 of this

notice are satisfied.

SECTION 3. WAIVER OF

UNDERPAYMENT OF ESTIMATED

INCOME TAX

Under the authority granted by section

6654(e)(3)(A), the addition to tax under

section 6654 for failure to make an estimated tax payment for the 2021 taxable

year is waived for any qualifying farmer

or fisherman who files a 2021 tax return

and pays in full any tax due on the return

by April 18, 2022, or, for those taxpayers

who live in Maine or Massachusetts, by

April 19, 2022. The waiver will apply to

any taxpayer who is a qualifying farmer

or fisherman for the 2021 taxable year and

fulfills the conditions stated in the previous sentence.

The waiver will apply automatically to any taxpayer who qualifies for the

waiver and does not report an addition to

tax under section 6654 on the 2021 tax

return. Taxpayers who otherwise satisfy

the criteria for relief under this notice,

but already filed a return and reported an

addition to tax under section 6654, may

request an abatement of the addition to

tax by filing Form 843, Claim for Refund

and Request for Abatement, in accordance with the Instructions for Form 843

and as follows:

• Write “Request for Relief under

Notice 2022-13” at the top of Form

843.

• Enter “6654” on line 4.

• Check the third box on line 5a.

• On line 5b, show the dates of any

payment of tax liability and addition

to tax under section 6654 for the tax

period involved.

• On line 7, state why the taxpayer’s

circumstances satisfy the criteria for

relief under this notice. Generally,

this would include the status of the

taxpayer as a qualifying farmer or

fisherman, filing a 2021 tax return,

and paying in full any tax due on the

return by April 18, 2022, or, for those

taxpayers who live in Maine or Massachusetts, by April 19, 2022.

Bulletin No. 2022–14

SECTION 4. CONTACT

INFORMATION

Treasury weighted average rate under

§ 431(c)(6)(E)(ii)(I).

The principal author of this notice is

Alexander Wu of the Office of the Associate Chief Counsel (Procedure and Administration). For further information, please

contact Mr. Wu at (202) 317-6845 (not a

toll-free number).

YIELD CURVE AND SEGMENT

RATES

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

Notice 2022-14

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used under § 417(e)(3), and the 24-month average

segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice

provides guidance as to the interest rate on

30-year Treasury securities under § 417(e)

(3)(A)(ii)(II) as in effect for plan years

beginning before 2008 and the 30-year

Applicable Month

March 2022

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC

plans under § 414(y)) pursuant to § 412.

Section 430(h)(2) specifies the interest rates that must be used to determine

a plan’s target normal cost and funding

target. Under this provision, present value is generally determined using three

24-month average interest rates (“segment

rates”), each of which applies to cash

flows during specified periods. To the extent provided under § 430(h)(2)(C)(iv),

these segment rates are adjusted by the applicable percentage of the 25-year average

segment rates for the period ending September 30 of the year preceding the calendar year in which the plan year begins.1

However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly

yield curve in place of the segment rates.

Notice 2007-81, 2007-44 I.R.B. 899,

provides guidelines for determining the

monthly corporate bond yield curve, and

the 24-month average corporate bond

segment rates used to compute the target

normal cost and the funding target. Consistent with the methodology specified in

Notice 2007-81, the monthly corporate

bond yield curve derived from February

2022 data is in Table 2022-2 at the end

of this notice. The spot first, second, and

third segment rates for the month of February 2022 are, respectively, 1.88, 3.35,

and 3.70.

The 24-month average segment rates

determined

under

§ 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant to

§ 430(h)(2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. The 25-year average

segment rates for plan years beginning in

2021 and 2022 were published in Notice

2020-72, 2020-40 I.R.B. 789, and Notice

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

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate

bond segment rates applicable for March

2022 without adjustment for the 25-year

average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment

First Segment

Second Segment

0.87

2.64

25-YEAR AVERAGE SEGMENT

RATES

Section 9706(a) of the American Rescue Plan Act of 2021, Pub. L. No. 117-2

(the ARP), which was enacted on March

11, 2021, changes the 25-year average

segment rates and the applicable minimum and maximum percentages used

under § 430(h)(3)(C)(iv) of the Code to

adjust the 24-month average segment

rates.2 Prior to this change, the applicable

minimum and maximum percentages were

85% and 115% for a plan year beginning

in 2021, and 80% and 120% for plan year

beginning in 2022, respectively. After this

change, the applicable minimum and maximum percentages are 95% and 105% for

a plan year beginning in 2021 or 2022. In

addition, pursuant to this change, any 25year average segment rate that is less than

5% is deemed to be 5%.3

Pursuant to § 9706(c)(1) of the ARP,

these changes apply with respect to plan

Third Segment

3.28

years beginning on or after January 1,

2020. However, § 9706(c)(2) of the ARP

provides that a plan sponsor may elect not

to have these changes apply to any plan

year beginning before January 1, 2022.4

The adjusted 24-month average segment rates set forth in the chart below

reflect § 430(h)(2)(C)(iv) of the Code

as amended by § 9706(a) of the ARP.

These adjusted 24-month average segment rates apply only for plan years for

which an election under § 9706(c)(2) of

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount

of the full funding limitation under § 433(c)(7)(C)).

Section 80602 of the Infrastructure Investment and Jobs Act, Pub. L. 117-58, makes further changes to the time periods for which specified applicable minimum and maximum percentages

apply.

Pursuant to this change, the 25-year averages of the first segment rate for 2021 and 2022 are increased to 5.00% because those 25-year averages as originally published are below 5.00%.

This election may be made either for all purposes for which the amendments under § 9706 of the ARP apply or solely for purposes of determining the adjusted funding target attainment

percentage under § 436 of the Code for the plan year.

Bulletin No. 2022–14

941

April 4, 2022

the ARP is not in effect. For a plan year

for which such an election does not apply, the 24-month averages applicable

For Plan Years

Beginning In

for March 2022, adjusted to be within

the applicable minimum and maximum

percentages of the corresponding 25-year

average segment rates in accordance with

§ 430(h)(2)(C)(iv) of the Code, are as

follows:

Adjusted 24-Month Average Segment Rates

Applicable

First

Second

Month

Segment

Third

Segment

2021

March 2022

4.75

5.36

6.11

2022

March 2022

4.75

5.18

5.92

The adjusted 24-month average segment rates set forth in the chart below do

not reflect the changes to § 430(h)(2)(C)

(iv) of the Code made by § 9706(a) of the

ARP. These adjusted 24-month average

For Plan Years

Beginning In

2021

segment rates apply only for plan years

for which an election under § 9706(c)(2)

of the ARP is in effect. For a plan year

for which such an election applies, the

24-month averages applicable for March

2022, adjusted to be within the applicable

minimum and maximum percentages of

the corresponding 25-year average segment rates in accordance with § 430(h)(2)

(C)(iv) of the Code, are as follows:

Pre-ARP Adjusted 24-Month Average Segment Rates

Applicable

First

Second

Month

Segment

March 2022

30-YEAR TREASURY SECURITIES

INTEREST RATES

3.32

Third

Segment

4.79

5.47

Section 431 specifies the minimum

funding requirements that apply to multiemployer plans pursuant to § 412. Section

431(c)(6)(B) specifies a minimum amount

for the full-funding limitation described

in § 431(c)(6)(A), based on the plan’s

current liability. Section 431(c)(6)(E)(ii)

(I) provides that the interest rate used to

calculate current liability for this purpose

must be no more than 5 percent above

and no more than 10 percent below the

weighted average of the rates of interest

on 30-year Treasury securities during the

four-year period ending on the last day before the beginning of the plan year. Notice

88-73, 1988-2 C.B. 383, provides guidelines for determining the weighted average interest rate. The rate of interest on

30-year Treasury securities for February

For Plan Years

Beginning In

Treasury Weighted Average Rates

30-Year Treasury

Weighted Average

Permissible Range

90% to 105%

March 2022

2.09

1.89 to 2.20

under § 417(e)(3)(D) are segment rates

computed without regard to a 24-month

average. Notice 2007-81 provides guidelines for determining the minimum present

value segment rates. Pursuant to that notice, the minimum present value segment

rates determined for February 2022 are as

follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

February 2022

April 4, 2022

2022 is 2.25 percent. The Service determined this rate as the average of the daily determinations of yield on the 30-year

Treasury bond maturing in February 2052.

For plan years beginning in March 2022,

the weighted average of the rates of interest on 30-year Treasury securities and the

permissible range of rates used to calculate current liability are as follows:

Minimum Present Value Segment Rates

First Segment

Second Segment

1.88

3.35

Third Segment

3.70

942

Bulletin No. 2022–14

DRAFTING INFORMATION

The principal author of this notice is

Tom Morgan of the Office of the Associate

Bulletin No. 2022–14

Chief Counsel (Employee Benefits, Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

943

of this guidance. For further information

regarding this notice, contact Mr. Morgan

at 202-317-6700 or Osmundo Bernabe at

626-927-1344 (not toll-free numbers).

April 4, 2022

Table 2022-2

Monthly Yield Curve for February 2022

Derived from February 2022 Data

Maturity

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

7.5

8.0

8.5

9.0

9.5

10.0

10.5

11.0

11.5

12.0

12.5

13.0

13.5

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

18.5

19.0

19.5

20.0

Yield

0.79

1.22

1.59

1.86

2.03

2.14

2.21

2.27

2.32

2.39

2.46

2.54

2.63

2.73

2.82

2.91

3.00

3.09

3.17

3.24

3.31

3.37

3.43

3.48

3.52

3.55

3.58

3.61

3.63

3.65

3.66

3.67

3.68

3.69

3.70

April 4, 2022

Maturity

20.5

21.0

21.5

22.0

22.5

23.0

23.5

24.0

24.5

25.0

25.5

26.0

26.5

27.0

27.5

28.0

28.5

29.0

29.5

30.0

30.5

31.0

31.5

32.0

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

38.0

38.5

39.0

39.5

40.0

Yield

3.70

3.69

3.70

Maturity

40.5

41.0

41.5

42.0

42.5

43.0

43.5

44.0

44.5

45.0

45.5

46.0

46.5

47.0

47.5

48.0

48.5

49.0

49.5

50.0

50.5

51.0

51.5

52.0

52.5

53.0

53.5

54.0

54.5

55.0

55.5

56.0

56.5

57.0

57.5

58.0

58.5

59.0

59.5

60.0

Yield

3.70

3.71

3.72

944

Maturity

60.5

61.0

61.5

62.0

62.5

63.0

63.5

64.0

64.5

65.0

65.5

66.0

66.5

67.0

67.5

68.0

68.5

69.0

69.5

70.0

70.5

71.0

71.5

72.0

72.5

73.0

73.5

74.0

74.5

75.0

75.5

76.0

76.5

77.0

77.5

78.0

78.5

79.0

79.5

80.0

Yield

3.72

Maturity

80.5

81.0

81.5

82.0

82.5

83.0

83.5

84.0

84.5

85.0

85.5

86.0

86.5

87.0

87.5

88.0

88.5

89.0

89.5

90.0

90.5

91.0

91.5

92.0

92.5

93.0

93.5

94.0

94.5

95.0

95.5

96.0

96.5

97.0

97.5

98.0

98.5

99.0

99.5

100.0

Yield

3.72

Bulletin No. 2022–14

26 CFR 601.601: Rules and Regulations.

(Also: §§ 147, 1.147(f)-1)

Rev. Proc. 2022-20

SECTION 1. PURPOSE

This revenue procedure provides guidance regarding the public approval requirement under § 147(f) of the Internal

Revenue Code for tax-exempt qualified

private activity bonds. Specifically, this

revenue procedure provides that hearings

held by teleconference as described in

section 4 of this revenue procedure will be

treated as held in a location that, based on

the facts and circumstances, is convenient

for residents of the approving governmental unit for the purpose of § 1.147(f)-1(d)

(2) of the Income Tax Regulations.

SECTION 2. BACKGROUND

.01 Pursuant to § 147(f), tax-exempt

qualified private activity bonds are subject

to a public approval requirement. Except

for refunding bonds described in § 147(f)

(2)(D), a bond issue must be approved by

the governmental unit issuing the bonds (or

on behalf of which such bonds are issued)

and by the governmental unit having jurisdiction over the area in which any facility

to be financed by the issue is located. Under § 147(f)(2)(B), an issue will be treated as having been approved by any governmental unit if the issue is approved by

the applicable elected representative of the

governmental unit after a public hearing

following reasonable public notice, or by

voter referendum of the governmental unit.

.02 Section 1.147(f)-1(d)(1) provides

that “public hearing” means a forum providing a reasonable opportunity for interested individuals to express their views,

orally or in writing, on the proposed issue of bonds and the location and nature

of the proposed project to be financed.

Section 1.147(f)-1(d)(2) provides that the

public hearing must be held in a location

that, based on the facts and circumstances, is convenient for residents of the approving governmental unit. The location

is presumed convenient for residents of

the approving governmental unit if the

public hearing is located in the approving governmental unit’s capital or seat

of government. Further, if more than one

Bulletin No. 2022–14

governmental unit is required to hold a

public hearing, the hearings may be combined as long as the combined hearing

affords the residents of all of the participating governmental units a reasonable

opportunity to be heard. The location of

any combined hearing is presumed convenient for residents of each participating

governmental unit if it is no farther than

100 miles from the seat of government of

each participating governmental unit beyond whose geographic jurisdiction the

hearing is conducted.

.03 In light of the Coronavirus Disease 2019 (COVID-19) pandemic, state

and local governmental units sought alternatives to in-person hearings held to

meet the public approval requirement. In

response to these concerns, Rev. Proc.

2020-21, 2020-22 I.R.B. 872, provides

temporary guidance regarding the public approval requirement under § 147(f).

Rev. Proc. 2020-21 provides that for the

period beginning May 4, 2020, and ending

on December 31, 2020 (time period limitation), hearings held by teleconference

that are accessible to the residents of the

approving governmental unit by calling a

toll-free telephone number will be treated as held in a location that, based on the

facts and circumstances, is convenient for

residents of the approving governmental

unit for purposes of § 1.147(f)-1(d)(2).

Rev. Proc. 2020-49, 2020-48 I.R.B. 1121,

modified section 4.02 of Rev. Proc. 202021 by extending the time period limitation

until September 30, 2021, and the time period limitation was further extended until

March 31, 2022, by Rev. Proc. 2021-39,

2021-38 I.R.B. 426, modifying sec. 4.02

of Rev. Proc. 2020-21, and modifying and

superseding Rev. Proc. 2020-49.

.04 The Department of the Treasury

(Treasury Department) and the Internal

Revenue Service (IRS) have received requests to permanently allow public hearings for qualified private activity bonds

to be held telephonically. In the past, the

Treasury Department and the IRS rejected

suggestions that an effective public hearing for qualified private activity bonds

may be held by teleconference or webinar. See TD 9845 (83 FR 67687 (Dec. 31,

2018)). The experience using telephonic

hearings during the COVID-19 pandemic has shown that telephonic access has in

fact made it easier for the public to express

945

its views regarding a proposed private activity bond issue and thus furthers the purpose of the public approval requirement in

§ 147(f). Accordingly, this revenue procedure provides the requested guidance by

eliminating the time period limitation on

holding public hearings telephonically.

SECTION 3. SCOPE

This revenue procedure applies to hearings held telephonically for the purpose of

satisfying the public approval requirement

under § 147(f).

SECTION 4. APPLICATION

A hearing that is held by teleconference

accessible to the residents of the approving governmental unit by calling a tollfree telephone number will be treated as

held in a location that, based on the facts

and circumstances, is convenient for residents of the approving governmental unit

for the purpose of § 1.147(f)-1(d)(2). Provided the requirements of the preceding

sentence are satisfied, governmental units

are not precluded from offering additional

access to the hearing by other telephone

numbers, internet-based meeting technology, or in-person attendance.

SECTION 5. EFFECT ON OTHER

DOCUMENTS

This revenue procedure modifies and

supersedes Rev. Proc. 2020-21 and Rev.

Proc. 2021-39.

SECTION 6. DATE OF

APPLICABILITY

This revenue procedure applies to public hearings held on or after March 18,

2022.

SECTION 7. DRAFTING

INFORMATION

The principal authors of this revenue

procedure are Johanna Som de Cerff and

David White of the Office of Associate

Chief Counsel (Financial Institutions &

Products). For further information regarding this revenue procedure, contact Ms.

Som de Cerff or Mr. White on (202) 3176980 (not a toll-free number).

April 4, 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. 2022–14

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.

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.

April 4, 2022

Numerical Finding List1

Bulletin 2022–14

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

AOD:

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

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

Notices:

Revenue Rulings:—Continued

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

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

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

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

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

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

Revenue Rulings:

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

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.

April 4, 2022

Bulletin No. 2022–14

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–14

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.

Bulletin No. 2022–14

iii

April 4, 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.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.