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In this episode
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)
Rev. Proc. 2022-19 — Published in Internal Revenue Bulletin No. 2022-41 on Oct. 11, 2022.
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