Internal Revenue Bulletin 2022-50 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 2022–50
December 12, 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, INCOME TAX
Rev. Proc. 2022-41, page 527.
This revenue procedure specifies when information
shown on a return in accordance with the applicable
forms and instructions will be an adequate disclosure
for purposes of reducing an understatement of income
tax under section 6662(d) and for purposes of avoid-
ing the section 6694(a) preparer penalty. This revenue
procedure updates Rev. Proc. 2021-52, 2021-51 I.R.B.
883, and applies to any income tax return filed on 2022
tax forms for a taxable year beginning in 2022, and to
any income tax return filed in 2023 on 2022 tax forms
for short taxable years beginning in 2023.
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.
December 12, 2022 Bulletin No. 2022–50

Part III
26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of
correct tax liability.
(Also: Part 1, §§ 6662, 6694, 1.6662-4, 1.6694-2)
Adequate Disclosure
Revenue Procedure
Renewal
Rev. Proc. 2022-41
SECTION 1. PURPOSE
This revenue procedure updates Rev.
Proc. 2021-52, 2021-51 I.R.B. 883, and
identifies circumstances under which the
disclosure on a taxpayer’s income tax
return with respect to an item or position
is adequate for the purpose of reducing
the understatement of income tax under
section 6662(d) of the Internal Revenue
Code (relating to the substantial under-
statement aspect of the accuracy-related
penalty), and for the purpose of avoid-
ing the tax return preparer penalty under
section 6694(a) (relating to understate-
ments due to unreasonable positions)
with respect to income tax returns. This
revenue procedure does not apply with
respect to any other penalty provisions
(including but not limited to the disre-
gard provisions of the section 6662(b)
(1) accuracy-related penalty, the section
6662(i) increased accuracy-related pen-
alty in the case of nondisclosed non-
economic substance transactions, and
the section 6662(b)(7) and (j) increased
accuracy-related penalty in the case of
undisclosed foreign financial asset under-
statements). If this revenue procedure
does not include an item or position, dis-
closure is adequate with respect to that
item or position only if made on a prop-
erly completed Form 8275 or 8275-R, as
appropriate, attached to the return for the
year or to a qualified amended return. See
Treas. Reg. § 1.6664-2(c) for information
about qualified amended returns.
This revenue procedure applies to any
income tax return filed on 2022 tax forms
for a taxable year beginning in 2022, and
to any income tax return filed in 2023 on
2022 tax forms for short taxable years
beginning in 2023.
SECTION 2. CHANGES FROM REV.
PROC. 2021-52
Changes have been made in order to
update the taxable years to which this rev-
enue procedure applies. No substantive
changes have been made.
SECTION 3. BACKGROUND
.01 If section 6662 applies to any por-
tion of an underpayment of tax required to
be shown on a return, an amount generally
equal to 20 percent of the portion of the
underpayment is added to the tax. Under
section 6662(b)(2), the penalty applies to
the portion of any underpayment of tax
that is attributable to a substantial under-
statement of income tax. The penalty rate
increases to 40 percent in the case of gross
valuation misstatements under section
6662(h), nondisclosed noneconomic sub-
stance transactions under section 6662(i),
or undisclosed foreign financial asset
understatements under section 6662(j).
.02 Generally, there is a substan-
tial understatement of income tax if the
amount of the understatement exceeds
the greater of (i) 10 percent of the amount
of tax required to be shown on the return
for the taxable year or (ii) $5,000. Section
6662(d)(1). Section 6662(d)(1)(C) pro-
vides a special rule for taxpayers claiming
a section 199A deduction. In the case of
any taxpayer who claims any deduction
allowed under section 199A for the tax-
able year, there is a substantial understate-
ment of income tax if the amount of the
understatement exceeds the greater of (i)
5 percent of the amount of tax required
to be shown on the return for the taxable
year or (ii) $5,000. Section 6662(d)(1)(B)
provides a special rule for corporations.
A corporation (other than an S corpora-
tion or a personal holding company) has
a substantial understatement of income
tax if the amount of the understatement
exceeds the lesser of (i) 10 percent of the
tax required to be shown on the return for
a taxable year (or, if greater, $10,000) or
(ii) $10,000,000. Generally, an under-
statement is the excess of the amount of
tax required to be shown on the return for
the taxable year over the amount of the
tax that is shown on the return reduced
by any rebate, where the excess is deter-
mined without regard to items to which
the reportable transaction understatement
penalty under section 6662A applies.
Section 6662(d)(2)(A). For purposes of
determining whether an understatement
is substantial, the understatement deter-
mined under the general rule is increased
by the aggregate amount of any reportable
transaction understatements relating to the
return. Section 6662A(e)(1)(A).
.03 In the case of an item not attribut-
able to a tax shelter, if the taxpayer has a
reasonable basis for the tax treatment of
the item, the amount of the understate-
ment is reduced by the portion of the
understatement attributable to the item
with respect to which the relevant facts
affecting the item’s tax treatment are
adequately disclosed in the return or in a
statement attached to the return. Section
6662(d)(2)(B)(ii).
.04 Section 6694(a) imposes a penalty
on a tax return preparer who prepares
a return or claim for refund reflecting
an understatement of liability due to an
“unreasonable position” if the tax return
preparer knew (or reasonably should have
known) of the position. A position (other
than a position with respect to a tax shelter
or a reportable transaction to which sec-
tion 6662A applies) is generally treated
as unreasonable unless (i) there is or was
substantial authority for the position, or
(ii) the position was properly disclosed
in accordance with section 6662(d)(2)(B)
(ii)(I) and had a reasonable basis. If the
position is with respect to a tax shelter
(as defined in section 6662(d)(2)(C)(ii))
or a reportable transaction to which sec-
tion 6662A applies, the position is treated
as unreasonable unless it is reasonable
to believe that the position would more
likely than not be sustained on the merits.
See Notice 2009-5, 2009-3 I.R.B. 309, for
interim penalty compliance rules for tax
shelter transactions.
.05 In general, this revenue proce-
dure provides guidance for determining
when disclosure by return is adequate
for purposes of section 6662(d)(2)(B)(ii)
and section 6694(a)(2)(B). For purposes
of this revenue procedure, the taxpayer
must furnish all required information in
accordance with the applicable forms
Bulletin No. 2022–50 527 December 12, 2022

and instructions, and the money amounts
entered on these forms must be verifiable.
.06 This revenue procedure may apply
to a return for a fiscal tax year that begins
in 2022 and ends in 2023. This revenue
procedure may also apply to a short year
return for a period beginning in 2023 if
the return is to be filed before the 2023
forms are available. (Note that individu-
als are generally not put in this position.)
The most frequent situation in which a
short year arises is when filing a dece-
dent’s final return for a fractional part of a
year. In that situation, the 2023 form will
be available because the final return is
due the fifteenth day of the fourth month
following the close of the 12-month
period that began with the first day of
such fractional part of the year (mean-
ing the due date is not accelerated). See
Treas. Reg. § 1.6072-1(b). In the case of
fiscal year and short year returns, the tax-
payer must take into account any tax law
changes that are effective for tax years
beginning after December 31, 2022, even
though these changes are not reflected on
the form or instructions.
.07 This document does not take into
account the effect of tax law changes
effective for tax years beginning after
December 31, 2022. If a line referenced in
this revenue procedure is affected by such
a change and requires additional reporting,
a taxpayer may have to file Form 8275,
Disclosure Statement, or Form 8275-R,
Regulation Disclosure Statement, until the
Service prescribes criteria for complying
with the requirement.
.08 A complete and accurate disclosure
of a tax position on the appropriate year’s
Schedule UTP, Uncertain Tax Position
Statement, will be treated as if the corpo-
ration filed a Form 8275 or Form 8275-R
regarding the tax position. The filing of
a Form 8275 or Form 8275-R, however,
will not be treated as if the corporation
filed a Schedule UTP.
SECTION 4. PROCEDURE
.01 General
(1) Additional disclosure of facts rel-
evant to, or positions taken with respect
to, issues involving any of the items
set forth below is unnecessary for pur-
poses of reducing any understatement of
income tax under section 6662(d) (except
as otherwise provided in section 4.02(3)
concerning Schedules M-1 and M-3), pro-
vided that the forms and attachments are
completed in a clear manner and in accor-
dance with their instructions.
(2) The money amounts entered on the
forms must be verifiable, and the informa-
tion on the return must be disclosed in the
manner described below. For purposes of
this revenue procedure, a number is veri-
fiable if, on audit, the taxpayer can prove
the origin of the amount (even if that
number is not ultimately accepted by the
Service) and the taxpayer can show good
faith in entering that number on the appli-
cable form.
(3) The disclosure of an amount as
provided in section 4.02 below is not
adequate when the understatement arises
from a transaction between parties who
are related within the meaning of section
267(b). If an entry may present a legal
issue or controversy because of a relat-
ed-party transaction, then that transaction
and the relationship must be disclosed on
a Form 8275 or Form 8275-R.
(4) When the amount of an item is
shown on a line that does not have a pre-
printed description identifying that item
(such as on an unnamed line under an
“Other Expense” category), the taxpayer
must clearly identify the item by including
the description on that line. For example,
to disclose a bad debt for a sole proprietor-
ship, the words “bad debt” must be written
or typed on the line of Schedule C (Form
1040 or 1040SR) that shows the amount
of the bad debt. Also, for Schedule M-3
(Form 1120), Part II, line 25, Other income
(loss) items with differences, or Part III,
line 38, Other expense/deduction items
with differences, the entry must provide
descriptive language; for example, “Cost
of non-compete agreement deductible not
capitalizable,” and the description must be
provided on an attachment. Similarly, for
other forms, if space limitations on a form
do not allow for an adequate description,
the description must be continued on an
attachment.
(5) Although a taxpayer may literally
meet the disclosure requirements of this
revenue procedure, the disclosure will
have no effect for purposes of the section
6662 accuracy-related penalty if the item
or position on the return (1) does not have
a reasonable basis as defined in Treas.
Reg. § 1.6662-3(b)(3); (2) is attributable
to a tax shelter item as defined in section
6662(d)(2)(C)(ii); or (3) is not properly
substantiated or the taxpayer failed to
keep adequate books and records with
respect to the item or position.
(6) Disclosure also will have no effect
for purposes of the section 6694(a) pen-
alty as applicable to tax return preparers if
the position is with respect to a tax shelter
(as defined in section 6662(d)(2)(C)(ii)) or
a reportable transaction to which section
6662A applies.
.02 Items
(1) Form 1040, Schedule A, Itemized
Deductions:
(a) Medical and Dental Expenses:
Complete lines 1 through 4, supplying all
required information.
(b) Taxes: Complete lines 5 through 7,
supplying all required information. Line 6
must list each type of tax and the amount
paid.
(c) Interest Expenses: Complete lines 8
through 10, supplying all required infor-
mation. This section 4.02(1)(c) does not
apply to (i) amounts disallowed under sec-
tion 163(d) unless Form 4952, Investment
Interest Expense Deduction, is completed,
or (ii) amounts disallowed under section
265.
(d) Charitable Contributions: Complete
lines 11 through 14, supplying all required
information and attaching all related forms
required pursuant to statute or regulation.
(e) Casualty and Theft Losses: Com-
plete Form 4684, Casualties and Thefts,
and attach to the return. Each item or arti-
cle for which a casualty or theft loss is
claimed must be listed on Form 4684.
(2) Certain Trade or Business Expenses
(including, for purposes of this section,
the following six expenses as they relate
to the rental of property):
(a) Casualty and Theft Losses: The
procedure outlined in section 4.02(1)(e)
must be followed.
(b) Legal Expenses: The amount
claimed must be stated. This section does
not apply, however, to amounts properly
characterized as capital expenditures, per-
sonal expenses, or non-deductible lobby-
ing or political expenditures, including
amounts that are required to be (or that
are) amortized over a period of years.
(c) Specific Bad Debt Charge-off: The
amount written off must be stated.
December 12, 2022 528 Bulletin No. 2022–50

Bulletin No. 2022–50 529 December 12, 2022
(d) Officers’ Compensation: Complete
Form 1125-E, Compensation of Officers,
when its instructions require completion.
You must express the “percent of time
devoted to business” as a numerical per-
centage, rather than as a non-numerical
description such as “part” or “as needed.”
This section does not apply to “excess
parachute payments,” as defined in sec-
tion 280G. This section does not apply
to the extent that remuneration paid or
incurred exceeds an applicable employ-
ee-remuneration deduction limitation
under section 162(m).
(e) Repair Expenses: The amount
claimed must be stated. This section does
not apply, however, to any amount prop-
erly characterized as capital expenditures
or personal expenses.
(f) Taxes (other than foreign taxes):
The amount claimed must be stated.
(3) Differences in book and income tax
reporting:
For Schedule M-1 and all Schedules
M-3, including those listed in (a)-(f)
below, the information provided must
reasonably apprise the Service of the
potential controversy concerning the tax
treatment of the item. If the information
provided does not so apprise the Service, a
Form 8275 or Form 8275-R must be used
to adequately disclose the item (see Part II
of the instructions for those forms).
Note: An item reported on a line with
a pre-printed description, shown on
an attached schedule or “itemized”
on Schedule M-1, may represent the
aggregate amount of several trans-
actions producing that item (i.e.,
a group of similar items, such as
amounts paid or incurred for supplies
by a taxpayer engaged in business).
In some instances, a potentially con-
troversial item may involve a portion
of the aggregate amount disclosed on
the schedule. The Service will not be
reasonably apprised of a potential con-
troversy by the aggregate amount dis-
closed. In these instances, the taxpayer
must use Form 8275 or Form 8275-R
regarding that portion of the item.
Combining unlike items, whether
on Schedule M-1 or Schedule M-3 (or
on an attachment when directed by the
instructions), will not constitute an ade-
quate disclosure.
Additionally, taxpayers that file the
Schedule M-3 (Form 1120), Net Income
(Loss) Reconciliation for Corporations
With Total Assets of $10 Million or More,
may be required to complete Schedule B
(Form 1120), Additional Information for
Schedule M-3 Filers. For further infor-
mation, see Who Must File in the General
Instructions for Schedule B (Form 1120).
Taxpayers that file the Schedule M-3
(Form 1065), Net Income (Loss) Recon-
ciliation for Certain Partnerships, may be
required to complete Schedule C (Form
1065), Additional Information for Sched-
ule M-3 Filers. For further information,
see Who Must File in the General Instruc-
tions for Schedule C (Form 1065). When
required, these schedules are necessary to
constitute adequate disclosure:
(a) Form 1065. Schedule M-3 (Form
1065), Net Income (Loss) Reconciliation
for Certain Partnerships:
Part II (reconciliation of income
(loss) items)
Column (a), Income (Loss) per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Income (Loss) per Tax Return
Part III (reconciliation of
expense/deduction items)
Column (a), Expense per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Deduction per Tax Return
(b) Form 1120. (i) Schedule M-1, Reconciliation of Income (Loss) per Books With Income per Return.
(ii) Schedule M-3 (Form 1120), Net Income (Loss) Reconciliation for Corporations With Total Assets of $10 Million or More:
Part II (reconciliation of income
(loss) items)
Column (a), Income (Loss) per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Income (Loss) per Tax Return
Part III (reconciliation of
expense/deduction items)
Column (a), Expense per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Deduction per Tax Return

December 12, 2022 530 Bulletin No. 2022–50
(c) Form 1120-L. Schedule M-3 (Form 1120-L), Net Income (Loss) Reconciliation for U.S. Life Insurance Companies With Total
Assets of $10 Million or More:
Part II (reconciliation of income
(loss) items)
Column (a), Income (Loss) per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Income (Loss) per Tax Return
Part III (reconciliation of
expense/deduction items)
Column (a), Expense per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Deduction per Tax Return
(d) Form 1120-PC. Schedule M-3 (Form 1120-PC), Net Income (Loss) Reconciliation for U.S. Property and Casualty Insurance
Companies With Total Assets of $10 Million or More:
Part II (reconciliation of income
(loss) items)
Column (a), Income (Loss) per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Income (Loss) per Tax Return
Part III (reconciliation of
expense/deduction items)
Column (a), Expense per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Deduction per Tax Return
(e) Form 1120-S. Schedule M-3 (Form 1120-S), Net Income (Loss) Reconciliation for S Corporations With Total Assets of $10
Million or More:
Part II (reconciliation of income
(loss) items)
Column (a), Income (Loss) per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Income (Loss) per Tax Return
Part III (reconciliation of
expense/deduction items)
Column (a), Expense per Income Statement;
Column (b), Temporary Difference;
Column (c), Permanent Difference; and
Column (d), Deduction per Tax Return
(f) Form 1120-F. Schedule M-3 (Form 1120-F), Net Income (Loss) Reconciliation for Foreign Corporations With Reportable
Assets of $10 Million or More:
Part II (reconciliation of income
(loss) items)
Column (b), Temporary Differences;
Column (c), Permanent Differences; and
Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI
Part III (reconciliation of
expense/deduction items)
Column (b), Temporary Differences;
Column (c), Permanent Differences; and
Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI

Bulletin No. 2022–50 531 December 12, 2022
(4) Foreign Tax Items:
(a) International Boycott Transactions:
Transactions disclosed on Form 5713,
International Boycott Report; Schedule
A, International Boycott Factor (Sec-
tion 999(c)(1)); Schedule B, Specifically
Attributable Taxes and Income (Section
999(c)(2)); and Schedule C, Tax Effect
of the International Boycott Provisions,
must be completed when required by their
instructions.
(b) Treaty-Based Return Position:
Transactions and amounts under sec-
tion 6114 or section 7701(b) as disclosed
on Form 8833, Treaty-Based Return
Position Disclosure Under Section 6114
or 7701(b), must be completed when
required by its instructions.
(5) Other:
(a) Moving Expenses: Complete Form
3903, Moving Expenses, and attach to the
return.
(b) Employee Business Expenses:
Complete Form 2106, Employee Business
Expenses (for use only by Armed Forces
reservists, qualified performing artists,
fee-basis state or local government officials,
and employees with impairment-related
work expenses), and attach to the return.
This section does not apply to club dues or
to travel expenses for any non-employee
accompanying the taxpayer on the trip.
(c) Fuels Credit: Complete Form 4136,
Credit for Federal Tax Paid on Fuels, and
attach to the return.
(d) Investment Credit: Complete Form
3468, Investment Credit, and attach to the
return.
SECTION 5. EFFECTIVE DATE
This revenue procedure applies to any
income tax return filed on a 2022 tax form
for a taxable year beginning in 2022 and
to any income tax return filed on a 2022
tax form in 2023 for a short taxable year
beginning in 2023.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Jesse Hubbard of the Office of
the Associate Chief Counsel (Procedure &
Administration). For further information
regarding this revenue procedure, contact
Branch 2 of Procedure and Administration
at (202) 317-6844 (not a toll free number).

Bulletin No. 2022–50 i December 12, 2022
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior 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.

December 12, 2022 ii Bulletin No. 2022–50
Numerical Finding List
1
Bulletin 2022–50
Announcements:
2022-14, 2022-31 I.R.B. 136
2022-15, 2022-31 I.R.B. 136
2022-16, 2022-33 I.R.B. 144
2022-17, 2022-35 I.R.B. 179
2022-18, 2022-36 I.R.B. 190
2022-19, 2022-36 I.R.B. 191
2022-20, 2022-38 I.R.B. 238
2022-21, 2022-46 I.R.B. 464
2022-22, 2022-47 I.R.B. 497
2022-23, 2022-48 I.R.B. 499
Notices:
2022-29, 2022-28 I.R.B. 66
2022-30, 2022-28 I.R.B. 70
2022-31, 2022-29 I.R.B. 85
2022-32, 2022-32 I.R.B. 137
2022-33, 2022-34 I.R.B. 147
2022-34, 2022-34 I.R.B. 150
2022-35, 2022-36 I.R.B. 184
2022-36, 2022-36 I.R.B. 188
2022-37, 2022-37 I.R.B. 234
2022-38, 2022-39 I.R.B. 239
2022-39, 2022-40 I.R.B. 264
2022-40, 2022-40 I.R.B. 266
2022-42, 2022-41 I.R.B. 276
2022-44, 2022-41 I.R.B. 277
2022-43, 2022-42 I.R.B. 303
2022-45, 2022-42 I.R.B. 307
2022-41, 2022-43 I.R.B. 304
2022-46, 2022-43 I.R.B. 306
2022-47, 2022-43 I.R.B. 312
2022-48, 2022-43 I.R.B. 316
2022-49, 2022-43 I.R.B. 321
2022-50, 2022-43 I.R.B. 325
2022-51, 2022-43 I.R.B. 331
2022-52, 2022-43 I.R.B. 337
2022-53, 2022-45 I.R.B. 437
2022-54, 2022-45 I.R.B. 439
2022-55, 2022-45 I.R.B. 443
2022-56, 2022-47 I.R.B. 480
2022-57, 2022-47 I.R.B. 482
2022-58, 2022-47 I.R.B. 483
2022-59, 2022-48 I.R.B. 498
2022-60, 2022-49 I.R.B. 502
2022-62, 2022-49 I.R.B. 506
Proposed Regulations:
REG-130975-08, 2022-28 I.R.B. 71
REG 130675-17, 2022-30 I.R.B. 104
REG-125693-19, 2022-39 I.R.B. 241
REG-110368-22, 2022-44 I.R.B. 405
Proposed Regulations:—Continued
REG-100719-21, 2022-45 I.R.B. 457
REG-121509-00, 2022-45 I.R.B. 463
REG-112096-22, 2022-49 I.R.B. 511
Revenue Procedures:
2022-25, 2022-27 I.R.B. 3
2022-28, 2022-27 I.R.B. 65
2022-26, 2022-29 I.R.B. 90
2022-32, 2022-30 I.R.B. 101
2022-30, 2022-31 I.R.B. 112
2022-29, 2022-33 I.R.B. 141
2022-34, 2022-33 I.R.B. 143
2022-35, 2022-40 I.R.B. 270
2022-36, 2022-40 I.R.B. 274
2022-19, 2022-41 I.R.B. 282
2022-31, 2022-43 I.R.B. 339
2022-37, 2022-43 I.R.B. 377
2022-38, 2022-45 I.R.B. 445
2022-40, 2022-47 I.R.B. 487
2022-39, 2022-49 I.R.B. 507
2022-41, 2022-50 I.R.B. 527
Revenue Rulings:
2022-12, 2022-27 I.R.B. 1
2022-13, 2022-30 I.R.B. 99
2022-14, 2022-31 I.R.B. 110
2022-15, 2022-35 I.R.B. 152
2022-17, 2022-36 I.R.B. 182
2022-18, 2022-40 I.R.B. 262
2022-19, 2022-44 I.R.B. 379
2022-20, 2022-45 I.R.B. 407
2022-21, 2022-47 I.R.B. 468
2022-22, 2022-49 I.R.B. 500
Treasury Decisions:
9963, 2022-34 I.R.B. 145
9964, 2022-35 I.R.B. 172
9965, 2022-37 I.R.B. 192
9966, 2022-44 I.R.B. 380
9967, 2022-44 I.R.B. 385
9968, 2022-45 I.R.B. 409
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. 2022–50 iii December 12, 2022
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2022–50
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.

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