This is the table of contents of Internal Revenue Bulletin IRB 2022-49. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.
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.
The revenue procedure obsoletes and replaces existing Revenue Procedure 94-69, 1994-2 C.B. 804. The revenue procedure prescribes special procedures for certain eligible LB&I taxpayers who are subject to nearly annual examinations to file a qualified amended return shortly after the opening of an audit. Eligible taxpayers may submit a form to report additional tax due or make an adequate disclosure with respect to an item or position to avoid the accuracy-related penalty described in sections 6662(b)(1) and 6662(b)(2).
26 CFR 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability
(Also: Part I, §§ 6662, 6664; 1.6662-3, 1.6662-4, 1.6664-2.)
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2022 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2022, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
This notice sets forth the 2022 Required Amendments List (2022 RA List). The 2022 RA List applies to both individually designed plans qualified under section 401(a) of the Internal Revenue Code (qualified individually designed plans) and individually designed plans that satisfy the requirements of section 403(b) (section 403(b) individually designed plans).
This document contains proposed regulations that clarify and revise certain foreign tax credit regulations that were published on January 4, 2022. Specifically, these proposed regulations amend the definition of a reattribution asset for purposes of allocating and apportioning foreign income taxes; revise the cost recovery rule under the requirements for a tax to be a creditable foreign income tax; and provide a limited exception to the source-based attribution requirement for withholding taxes imposed on royalty payments to be creditable foreign income taxes.
Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term tax exempt rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for December 2022.
(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)
The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.