us-irs-announcements-irb-2022-33-pdf•Internal Revenue Bulletin 2022-33 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 2022-33 (PDF rendition): IRS Announcements
us-irs-announcements-irb-2022-33-pdfInternal Revenue Bulletin 2022-33 (PDF rendition): IRS AnnouncementsGuidance
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Bulletin No. 2022–33 August 15, 2022 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 Rev. Proc. 2022-29, page 141. This revenue procedure modifies and supersedes Rev- enue Procedure 2006-36, 2006-38 I.R.B 498. It sets forth the procedures for other Government agencies and members of the public to request the creation of special statistical studies and compilations involving return information pursuant to section 6108(b) of the Internal Revenue Code. It further sets forth the criteria for determining reasonable fees for costs associated with the creation of the special statistical studies and compilations. Rev. Proc. 2022-34, page 143. This revenue procedure provides indexing adjustments for certain provisions under § 36B of the Internal Revenue Code (Code). In particular, it updates the applicable percentage table in § 36B(b)(3)(A)(i) used to calculate an individual’s premium tax credit for calendar year 2023. The revenue procedure also updates the required contribution percentage in § 36B(c)(2)(C)(i)(II) for plan years beginning after calendar year 2022. This percentage is used to determine whether an individual is eligible for affordable employer-sponsored minimum essential coverage under § 36B. EXEMPT ORGANIZATIONS Announcement 2022-16, page 144. Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A). Finding Lists begin on page ii. 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 offi- cial 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 sub- stantive 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 other- wise indicated. Procedures relating solely to matters of inter- nal 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 rul- ings 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, disbar- ment and suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. August 15, 2022 Bulletin No. 2022–33 Part III 26 U.S.C. 6108(b): Special Statistical Studies Rev. Proc. 2022-29 SECTION 1. PURPOSE This revenue procedure modifies and supersedes Rev. Proc. 2006-36, 2006- 38 I.R.B. 498 (September 18, 2006) to update the procedures for other Govern- ment agencies or members of the public to request the Internal Revenue Service (IRS) to create special statistical stud- ies and compilations involving return information pursuant to § 6108(b) of the Internal Revenue Code (Code), and to set forth the criteria for determining reason- able fees for costs associated with the cre- ation of the special statistical studies and compilations. SECTION 2. NATURE OF CHANGES .01 Section 2.01 of Rev. Proc. 2006-36 is updated as follows: (1) To describe the IRS’s authority to prescribe reasonable fees for the cost of work or services performed to create spe- cial statistical studies and compilations. (2) To clarify that fees are charged only for a special statistical study or compi- lation that does not primarily benefit the public. .02 Section 2.02(c)(ii) of Rev. Proc. 2006-36 is revised to update the list of electronic medium that are currently used by the offices processing requests to create special statistical studies and compilations. .03 Section 3.02 of Rev. Proc. 2006-36 is revised: (1) To reflect that requests to create special statistical studies and compilations may be submitted by mail or email and must be addressed to the Director, Statis- tics of Income Division (SOI). (2) To reflect a new address, phone number, and fax number for SOI. (3) To remove the last sentence pro- viding that a determination to grant or deny requests to create special statistical studies and compilations will be made in consultation with the Director, Office of Tax Analysis, Department of the Trea- sury (Treasury Department), if a signifi- cant amount of SOI resources are needed to accommodate a request. The Office of Tax Analysis, Treasury Department is not involved in determining whether to grant or deny requests to create special statisti- cal studies and compilations because SOI is recognized by the Director of the Office of Management and Budget (OMB) as a principal Federal statistical agency and therefore is required to develop its own policies regarding statistical releases. See Title III of the Foundations For Evi- dence-Based Policymaking Act of 2018, Public Law 115–435, 132 Stat. 5529, 5544- 5555 (44. U.S.C. §§ 3561-3583). .04 Section 5.01 of Rev. Proc. 2006-36 is updated to reflect that fees are charged to create special statistical studies and compilations only for a special statistical study or compilation that does not primar- ily benefit the public. SECTION 3. BACKGROUND .01 In general. Under § 6108(b), the IRS may, upon written request, create and produce special statistical studies and compilations involving return infor- mation (as defined by § 6103(b)(2) of the Code). In processing requests for special statistical studies and compilations, the IRS, pursuant to § 6108(c), will not dis- close information that could, directly or indirectly, be associated with or identify a particular taxpayer. Pursuant to its author- ity under § 6108(b), the IRS may charge a reasonable fee for the cost of work or services associated with making special statistical studies and compilations. Con- sistent with § 6(a)(1) of OMB Circular A-25, 1 fees will be charged only for a special statistical study or compilation that does not primarily benefit the public. A special statistical study or compilation that primarily benefits the public provides statistical information about the Federal tax system that is deemed pertinent and valuable to the public and can be pub- lished in conjunction with the IRS’s pub- lication of statistics pursuant to § 6108(a). The IRS will determine the amount of the fee as discussed in section 6 of this reve- nue procedure. .02 Definitions. (1) A “special statistical study” is an ad hoc statistical examination or analysis of return information that generally requires new programming and analysis according to specifications provided in the request. A special statistical study might com- prise tabulations as well as accompanying reports on methodology and analytical details. (2) A statistical “compilation” is an ad hoc accumulation of existing (or read- ily available) data into a data set or data file, which generally requires new pro- gramming according to specifications provided in the request. Both special sta- tistical studies and compilations will be reviewed for accuracy by IRS staff before they are considered completed. The IRS staff, including technical, administrative, and computer programming personnel, will ensure, as reasonably practicable, that the completed special statistical study or compilation reflects the specifications of the original request. (3) A special statistical study or com- pilation is not (i) statistical data con- tained in reports or releases already made available to the public, or (ii) statistical data that is readily reproducible. “Read- ily reproducible” means, with respect to electronic format, a record or records that can be downloaded or transferred intact to a universal serial bus (USB) flash drive, digital versatile disc (DVD), compact disk (CD), or other electronic medium using equipment currently in use by the office or offices processing the request. Records 1 As relevant to charging user fees, OMB Circular A-25 cites as its authority Title V of the Independent Offices Appropriations Act, 1952 (Public Law 37, 65 Stat. 268, 290 (1951)), codified at 31 U.S.C. 9701 by “A bill to revise, codify, and enact without substantive change certain general and permanent laws, related to money and finance, as title 31, United States Code, ‘Money and Finance’,” Public Law 97-258, 96 Stat. 877, 1051-1052 (1982). Bulletin No. 2022–33 141 August 15, 2022 that require manipulation of data within a database or several databases, reprogram- ming one or more databases, or analysis of the data to produce the records, are not readily reproducible. SECTION 4. PROCEDURES FOR REQUESTING SPECIAL STATISTICAL STUDIES AND COMPILATIONS PURSUANT TO § 6108(b) .01 In general. Requests for special sta- tistical studies or compilations (involving either new projects or changes in recur- ring projects) must be submitted in writ- ing with specifications as complete and definite as practical. Specifications that are concise and mutually understood by the requester and the IRS are essential for a project’s successful completion. Spec- ifications should include the source and availability of data and content, manner of presentation (for example, particular medium or application) and timing of results (for example, scheduling). .02 Submitting requests. All requests for special statistical studies or compila- tions must be addressed to the Director, SOI and emailed to SIS@IRS.GOV or mailed to the following address: Director, Statistics of Income Division Internal Revenue Service 1111 Constitution Avenue, NW Room K-4100 Washington, DC 20224 Attention: RAAS, Statistics of Income The Director, SOI, will review all requests for special statistical studies or compilations and make a determination whether to grant or deny the request for such special statistical studies or compi- lations based on the considerations stated in section 5.01 of this revenue procedure. If a significant amount of resources are needed to accommodate a request, such determination will be made in consulta- tion with the responsible IRS offices. .03 Consultation with SOI. If assistance is needed, SOI’s Statistical Information Services Office is available to help the requester in detailing the specifications of the request for a special study or com- pilation. Consultations at initial stages, that is, while planning by the requester is underway, may facilitate the undertaking of a special study or compilation. In some instances, initial consultation may reveal that an existing IRS product contains all the data necessary to fulfill the request. SOI’s Statistical Information Services Office may be reached by email at SIS@ IRS.GOV, by phone at (202) 803-9285 (not a toll-free number), by fax at (202) 803-9393, or by mail at the address pro- vided in section 4.02 of this revenue pro- cedure. In addition, there is information available on the IRS website at irs.gov/ statistics. SECTION 5. AVAILABILITY OF SPECIAL STATISTICAL STUDIES AND COMPILATIONS .01 The fulfillment of requests for spe- cial statistical studies or compilations sub- mitted pursuant to this revenue procedure will be subject to several factors, including staff availability and workload, the com- plexity and/or magnitude of the request, the impact on tax administration, software capabilities, database configurations and equipment functionalities, and disclosure considerations. A request will be declined if the IRS determines at the time of the initial request that the special statistical study or compilation could reveal return information or other taxpayer identifying information, the disclosure of which is not authorized by law, and no reconfigu- ration of the request can avoid disclosure of return information or other non-disclos- able data. .02 If the configuration of an ongoing special statistical study or compilation may result in the disclosure of return information, or if the identity of individ- ual taxpayers can reasonably be inferred by either direct or indirect means, the IRS will inform the requester and offer to discuss with the requester, to the extent practicable, possible reconfigurations of data to avoid the prohibited disclosure. If the special statistical study or compi- lation cannot be adequately reconfigured, the requester will be so informed, and the special statistical study or compilation will not be completed; nor will any infor- mation that has already been compiled be released. .03 In general, the IRS will consider whether to grant or deny requests for spe- cial statistical studies and compilations in the order of receipt. SECTION 6. DETERMINATION OF FEES .01 Fees will be charged for a special statistical study or compilation that does not primarily benefit the public. The IRS will determine whether a statistical study or compilation primarily benefits the pub- lic. Fees will be determined in accordance with prevailing Government standards, but in no case will work be done before a cost estimate is provided to the requester and, if accepted, a reimbursable agree- ment is entered into between IRS and the requester. .02 Consistent with § 6(a)(1) and (d) (1) of OMB Circular A-25, fees are based on the actual, full cost of providing the product or service. “Full cost” includes all direct and indirect costs to any part of the government of providing the special sta- tistical study or compilation. These costs include but are not limited to: (1) direct costs such as computer costs, salaries, management and supervisory costs; (2) indirect personnel costs such as fringe benefits, for example, medi- cal insurance and retirement (generally assessed at a percentage of direct salary costs); and (3) physical overhead, consulting, and other indirect costs such as material and supply costs and utilities. .03 The IRS may charge fees for any costs incurred during the processing of an accepted request for special statistical studies and compilations. SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES Rev. Proc. 2006-36, 2006-38 I.R.B. 498, is superseded. SECTION 8. EFFECTIVE DATE This revenue procedure is effective on August 1, 2022. SECTION 9. DRAFTING INFORMATION The principal author of this revenue procedure is Robert Bley of the Office of the Associate Chief Counsel (Proce- dure & Administration). However, other August 15, 2022 142 Bulletin No. 2022–33 Bulletin No. 2022–33 143 August 15, 2022 personnel from the IRS and the Treasury Department participated in the develop- ment of the revenue procedure. For fur- ther information regarding this revenue procedure contact Robert Bley at (202) 317-6834 (not a toll free number). 26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also Part 1, §§ 36B, 1.36B-2, 1.36B-3.) Rev. Proc. 2022-34 SECTION 1. PURPOSE This revenue procedure provides indexing adjustments for certain provi- sions under § 36B of the Internal Revenue Code (Code). In particular, it updates the applicable percentage table in § 36B(b) (3)(A)(i) (Applicable Percentage Table) for calendar year 2023. 1 This table is used to calculate an individual’s premium tax credit. The revenue procedure also updates the required contribution per- centage in § 36B(c)(2)(C)(i)(II) for plan years beginning after calendar year 2022 (Section 36B Required Contribution Per- centage). This percentage is used to deter- mine whether an individual is eligible for affordable employer-sponsored minimum essential coverage under § 36B. This rev- enue procedure uses the methodology described in section 4 of Rev. Proc. 2014- 37, 2014-2 C.B. 363, to index the Applica- ble Percentage Table and the Section 36B Required Contribution Percentage for cal- endar year 2023. The Applicable Percent- age Table and the Section 36B Required Contribution Percentage are indexed based on the rates of premium growth rel- ative to the rates of income growth. See §§ 1.36B-2(c)(3)(v)(C) and 1.36B-3(g)(1) of the Income Tax Regulations. The rates of premium growth and the rates of income growth are determined using the National Health Expenditure Accounts (NHEA) Projections published by the Centers for Medicare and Medicaid Services Office of the Actuary. 2 Rev. Proc. 2014-37, sec- tions 3.01, 3.02. In addition, the additional adjustment provided in § 36B(b)(3)(A)(ii) (II) is not required for plan years begin- ning in 2023 because the Department of the Treasury and the Internal Revenue Service have determined that the failsafe exception described in § 36B(b)(3)(A)(ii) (III) applies for plan years beginning in calendar year 2023. SECTION 2. ADJUSTED ITEMS .01 Applicable Percentage Table for 2023. For taxable years beginning in cal- endar year 2023, the Applicable Percent- age Table for purposes of § 36B(b)(3)(A) (i) and § 1.36B-3(g) of the Income Tax Regulations is: Household income percentage of Federal poverty line:Initial percentageFinal percentage Less than 133%1.92%1.92% At least 133% but less than 150%2.88%3.84% At least 150% but less than 200%3.84%6.05% At least 200% but less than 250%6.05%7.73% At least 250% but less than 300%7.73%9.12% At least 300% but not more than 400%9.12%9.12% .02 Section 36B Required Contribu- tion Percentage for 2023. For plan years beginning in calendar year 2023, the Sec- tion 36B Required Contribution Percent- age for purposes of § 36B(c)(2)(C)(i)(II) and § 1.36B-2(c)(3)(v)(C) is 9.12%. SECTION 3. EFFECT ON OTHER DOCUMENTS Rev. Proc. 2014-37 is supplemented. SECTION 4. EFFECTIVE DATE This revenue procedure is effective for taxable years and plan years beginning after December 31, 2022. SECTION 5. DRAFTING INFORMATION The principal author of this revenue procedure is Bill Ruane of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Mr. Ruane at (202) 317-4718 (not a toll- free number). 1 The American Rescue Plan Act of 2021, Public Law 117-2, 135 Stat. 4, 182 (2021), added § 36B(b)(3)(A)(iii) to the Code to provide an Applicable Percentage Table that applies for taxable years beginning in calendar years 2021 and 2022. Section 36B(b)(3)(A)(iii) also suspends indexing of the Applicable Percentage Table for the 2021 and 2022 taxable years. 2 The rate of premium growth and the rate of income growth for calendar year 2023 are calculated using the NHEA Projections, 2021-2030, available at: https://www.cms.gov/Research-Sta- tistics-Data-and-Systems/Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected, which reflect the most recent projections, and the methodology used to calculate the same rates of growth in the Premium Adjustment Percentage guidance for the 2023 benefit year published by the Center for Medicare and Medicaid Services on December 28, 2021, available at: https://www.cms.gov/files/document/2023-papi-parameters-guidance-v4-final-12-27-21-508.pdf. August 15, 2022 144 Bulletin No. 2022–33 Part IV Deletions From Cumulative List of Organizations, Contributions to Which are Deductible Under Section 170 of the Code Announcement 2022-16 Table of Contents The Internal Revenue Service has revoked its determination that the organi- zations listed below qualify as organiza- tions described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not pre- cluded from disallowing a deduction for any contributions made after an organiza- tion ceases to qualify under section 170(c) (2) if the organization has not timely filed a suit for declaratory judgment under sec- tion 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation. If on the other hand a suit for declar- atory judgment has been timely filed, contributions from individuals and orga- nizations described in section 170(c)(2) that are otherwise allowable will con- tinue to be deductible. Protection under section 7428(c) would begin on August 15, 2022 and would end on the date the court first determines the organization is not described in section 170(c)(2) as more particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a hus- band and wife treated as one contributor. This benefit is not extended to any indi- vidual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. NAME OF ORGANIZATION Effective Date of RevocationLOCATION Sasi, Inc.1/1/2017Lake Grove, NY AMERICAN FRIENDS OF THE JONATHAN INSTITUTE3/1/2017New York, NY United Lao Council for Peace Freedom and Reconstruction1/1/2017Sacramento, CA Yale Club of Princeton, Inc.4/1/2017Princeton, NJ Sherman Oaks Health System2/1/2017Los Angeles, CA Missouri Athletic Club Foundation for the Arts9/1/2016Saint Louis, MO CRYSTAL LAKE COUNTRY CLUB6/23/2021Crystal Lake, IL Mercy Foundation Group, Inc.1/1/2015Tampa, FL Community Link Foundation, Inc.1/1/2018Manchester, MI Service Dogs by Warren Retrievers, Inc.1/1/2017Culpepper, VA Creating A New Outlook, Inc.1/1/2018Milwaukee, WI WEST COAST CHARITY FOR THE CHILDREN1/1/2017Grants Pass, OR Cancer Support Services1/1/2014Nashville, TN Maritime Pilots Institute1/1/2018Covington, LA Sisterhood on the Move Inc.1/1/2017Mattapan, MA Marilyn Jane Foundation 6/4/2014Lake Orion, MI Batchu Foundation 2/6/2017Downers Grove, IL Giles County Partnership for Excellence7/1/2016Glen Lyn, VA High Rising Equine Rescue, Inc.1/1/2016Estell Manor, NJ Miyb California1/1/2016Santa Maria CA Save Our Children USA, Inc. 1/1/2017Saint Cloud, FL Bulletin No. 2022–33 i August 15, 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 pub- lished 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 confu- sion. It is not used where a position in a prior ruling is being changed. Distinguished describes a situation where a ruling mentions a previously pub- lished 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 pub- lished ruling that is not considered deter- minative 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 sub- stance 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 rul- ings in the series. Suspended is used in rare situations to show that the previous published rul- ings 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. 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. August 15, 2022 ii Bulletin No. 2022–33 Numerical Finding List 1 Bulletin 2022–33 Announcements: 2022-14, 2022-31 I.R.B. 136 2022-15, 2022-31 I.R.B. 136 2022-16, 2022-33 I.R.B. 144 Notices: 2022-29, 2022-28 I.R.B. 66 2022-30, 2022-28 I.R.B. 70 2022-31, 2022-29 I.R.B. 85 2022-32, 2022-32 I.R.B. 137 Proposed Regulations: REG-130975-08, 2022-28 I.R.B. 71 REG 130675-17, 2022-30 I.R.B. 104 Revenue Procedures: 2022-25, 2022-27 I.R.B. 3 2022-28, 2022-27 I.R.B. 65 2022-26, 2022-29 I.R.B. 90 2022-32, 2022-30 I.R.B. 101 2022-30, 2022-31 I.R.B. 112 2022-29, 2022-33 I.R.B. 141 2022-34, 2022-33 I.R.B. 143 Revenue Rulings: 2022-12, 2022-27 I.R.B. 1 2022-13, 2022-30 I.R.B. 99 2022-14, 2022-31 I.R.B. 110 1 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. Bulletin No. 2022–33 iii August 15, 2022 Finding List of Current Actions on Previously Published Items 1 Bulletin 2022–33 1 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. 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.
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