Episode Details

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.

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