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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.

Keep your finger on the pulse of the dynamic and evolving tax landscape with insights from tax thought leaders in the AICPA Tax Section. The Tax Section Odyssey podcast includes a digest of tax developments, trending issues and practice management tips that you need to be aware of to elevate your professional development and your firm practices.

This resource is part of the robust tax resource library available from the AICPA Tax Section. The Tax Section is your go-to home base for staying up to date on the latest tax developments and providing the edge you need for upskilling your professional development. If you’re not already a member, consider joining this prestigious community of your tax peers. You’ll get free CPE, access to rich technical content such as our Annual Tax Compliance Kit, a weekly member newsletter and a digital subscription to The Tax Adviser.