Feb 22, 2023
Rev. Proc. 2022-19 appears in the Internal Revenue Bulletin 2022-41 for Oct. 11, 2022, and provides taxpayer assistance procedures to allow S corporations and their shareholders to resolve frequently encountered issues without requesting a private letter ruling (PLR) issued by the Internal Revenue Service (IRS).
On this Tax Section Odyssey episode, April Walker, CPA, CGMA, Lead Manager — Tax Practice & Ethics, AICPA & CIMA, discusses the revenue procedure in detail with Tony Nitti, CPA, Partner — National Tax, EY. Tony combs through the circumstances in which a PLR will not be available or will not ordinarily be issued. In these cases, the IRS does not have a concern with the validity of the entity’s S corporation election or there are other avenues to address the matter outside of the PLR process.
What you’ll learn in this episode
- Setting the stage for Rev. Proc. 2022-19 (0.49)
- Generalization of the frequently encountered issues provided in Rev. Proc. 2022-19 (15.52)
- Principal purpose motivation (16.55)
- Disproportionate distributions (22.14)
- Missing shareholder consent (27.53)
- Missing an administrative letter relating to the IRS’s acceptance of an election (33.28
- Federal income tax return filing that is inconsistent with the entity’s S corporation status (34.20)
- Non-identical governing provisions (35.24)
- A word of caution (39.25)
- Tony’s final thoughts (43.57)
Related resources
- Rev. Proc. 2022-19 — Published in Internal Revenue Bulletin No. 2022-41 on Oct. 11, 2022.
- IRS Practice & Procedure — Browse the latest resources to help with IRS tax matters including news, guidance and tools.
- AICPA tax season library — With constant changes to the tax landscape, being prepared for tax season is critical for success. Set yourself up for a smoother filing season by tapping into the wealth of AICPA and Tax Section resources.
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