HIGHLIGHTS OF THIS ISSUE ADMINISTRATIVE The IRS Mission Introduction Part IV Announcement 2022-13 Definition of Terms Abbreviations Numerical Finding List1 Numerical Finding List Finding List of Current Actions on Previously Published Items1 How to get the Internal Revenue Bulletin INTERNAL REVENUE BULLETIN We Welcome Comments About the Internal Revenue Bulletin Internal Revenue Bulletin: 2022-26 June 27, 2022 HIGHLIGHTS OF THIS ISSUE 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. ADMINISTRATIVE Announcement 2022-13, page 1185. This Announcement advises the public that the Internal Revenue Service is revising the optional standard mileage rates for computing the deductible costs of operating an automobile for business, medical, or moving expense purposes and for determining the reimbursed amount of these expenses that is deemed substantiated. These revised rates are effective beginning July 1, 2022. This Announcement modifies Notice 2022-3. The IRS Mission Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. Part IV Optional Standard Mileage Rates Announcement 2022-13 This announcement informs taxpayers that the Internal Revenue Service is modifying Notice 2022-3, 2022-2 I.R.B. 308, by revising the optional standard mileage rates for computing the deductible costs of operating an automobile for business, medical, or moving expense purposes and for determining the reimbursed amount of these expenses that is deemed substantiated. This modification results from recent increases in the price of fuel. The revised standard mileage rates are: (1) Business 62.5 cents per mile (2) Medical and moving 22 cents per mile The mileage rate that applies to the deduction for charitable contributions is fixed under § 170(i) of the Internal Revenue Code (Code) at 14 cents per mile. The revised standard mileage rates set forth in this announcement apply to deductible transportation expenses paid or incurred for business, medical, or moving expense purposes on or after July 1, 2022, and to mileage allowances that are paid both (1) to an employee on or after July 1, 2022, and (2) for transportation expenses paid or incurred by the employee on or after July 1, 2022. The standard mileage rates set forth in Notice 2022-3 continue to apply to deductible transportation expenses paid or incurred for business, medical, or moving expense purposes before July 1, 2022, and to mileage allowances paid (1) to an employee before July 1, 2022, or (2) with respect to transportation expenses paid or incurred by the employee before July 1, 2022. All other provisions of Notice 2022-3 remain in effect. Note that § 11045 of Public Law 115- 97, 131. Stat. 2054 (December 22, 2017), commonly referred to as the Tax Cuts and Jobs Act (TCJA), suspends all miscellaneous itemized deductions that are subject to the two-percent of adjusted gross income floor under § 67 of the Code, including unreimbursed employee travel expenses, for taxable years beginning after December 31, 2017, and before January 1, 2026. Thus, the revised business standard mileage rate provided in this announcement cannot be used to claim an itemized deduction for unreimbursed employee travel expenses during the suspension. Notwithstanding the foregoing suspension of miscellaneous itemized deductions, deductions for expenses that are deductible in determining adjusted gross income are not suspended. For example, members of a reserve component of the Armed Forces of the United States (Armed Forces), state or local government officials paid on a fee basis, and certain performing artists are entitled to deduct unreimbursed employee travel expenses as an adjustment to total income on line 12 of Schedule 1 of Form 1040 (2021), U.S. Individual Income Tax Return, not as an itemized deduction on Schedule A of Form 1040 (2021), and therefore may use the revised business standard mileage rate provided in this announcement. Further, § 11049 of the TCJA suspends the deduction for moving expenses for taxable years beginning after December 31, 2017, and before January 1, 2026. However, the suspension does not apply to members of the Armed Forces on active duty who move pursuant to a military order and incident to a permanent change of station. Thus, except for taxpayers to whom § 217(g) of the Code applies, the revised standard mileage rate provided in this announcement is not applicable for the use of an automobile as part of a move occurring during the suspension. EFFECT ON OTHER DOCUMENTS Notice 2022-3 is modified. DRAFTING INFORMATION The principal author of this announcement is Christian Lagorio of the Office of Chief Counsel (Income Tax and Accounting). For further information regarding this announcement contact Mr. Lagorio at (202) 317-7005 (not a toll-free number). Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed. Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The following abbreviations in current use and formerly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statement of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Numerical Finding List1 Numerical Finding List Bulletin 2022–26 Announcements: Article Issue Link Page 2022-3 2022-8 I.R.B. 2022-08 788 2022-4 2022-9 I.R.B. 2022-09 789 2022-5 2022-11 I.R.B. 2022-11 825 2022-6 2022-13 I.R.B. 2022-13 934 2022-7 2022-15 I.R.B. 2022-15 946 2022-8 2022-19 I.R.B. 2022-19 1056 2022-9 2022-22 I.R.B. 2022-22 1153 2022-10 2022-22 I.R.B. 2022-22 1156 2022-11 2022-24 I.R.B. 2022-24 1183 2022-12 2022-25 I.R.B. 2022-25 1184 2022-13 2022-26 I.R.B. 2022-26 1185 AOD: Article Issue Link Page 2022-1 2022-06 I.R.B. 2022-06 466 2022-2 2022-12 I.R.B. 2022-12 903 Notices: Article Issue Link Page 2022-1 2022-02 I.R.B. 2022-02 304 2022-2 2022-02 I.R.B. 2022-02 304 2022-3 2022-02 I.R.B. 2022-02 308 2022-4 2022-02 I.R.B. 2022-02 309 2022-5 2022-05 I.R.B. 2022-05 457 2022-6 2022-05 I.R.B. 2022-05 460 2022-7 2022-06 I.R.B. 2022-06 469 2022-8 2022-07 I.R.B. 2022-07 491 2022-9 2022-10 I.R.B. 2022-10 811 2022-10 2022-10 I.R.B. 2022-10 815 2022-12 2022-12 I.R.B. 2022-12 906 2022-11 2022-14 I.R.B. 2022-14 939 2022-13 2022-14 I.R.B. 2022-14 940 2022-14 2022-14 I.R.B. 2022-14 941 2022-15 2022-18 I.R.B. 2022-18 1043 2022-16 2022-18 I.R.B. 2022-18 1044 2022-17 2022-18 I.R.B. 2022-18 1048 2022-18 2022-18 I.R.B. 2022-18 1048 2022-19 2022-18 I.R.B. 2022-18 1050 2022-21 2022-20 I.R.B. 2022-20 1057 2022-22 2022-20 I.R.B. 2022-20 1057 2022-23 2022-20 I.R.B. 2022-20 1062 2022-20 2022-21 I.R.B. 2022-21 1095 2022-24 2022-21 I.R.B. 2022-21 1097 2022-27 2022-22 I.R.B. 2022-22 1151 2022-25 2022-23 I.R.B. 2022-23 1178 2022-28 2022-28 I.R.B. 2022-28 1182 Proposed Regulations: Article Issue Link Page REG-118250-20 2022-07 I.R.B. 2022-07 753 REG-105954-20 2022-11 I.R.B. 2022-11 828 REG-114209-21 2022-11 I.R.B. 2022-11 898 REG-114209-21 2022-11 I.R.B. 2022-11 898 REG-121508-18 2022-15 I.R.B. 2022-15 996 Proposed Regulations:—Continued Article Issue Link Page REG-114339-21 2022-17 I.R.B. 2022-17 1030 REG-106384-20 2022-20 I.R.B. 2022-20 1076 REG-118913-21 2022-20 I.R.B. 2022-20 1089 REG-122770-18 2022-21 I.R.B. 2022-21 1104 Revenue Procedures: Article Issue Link Page 2022-1 2022-01 I.R.B. 2022-01 1 2022-2 2022-01 I.R.B. 2022-01 120 2022-3 2022-01 I.R.B. 2022-01 144 2022-4 2022-01 I.R.B. 2022-01 161 2022-5 2022-01 I.R.B. 2022-01 256 2022-7 2022-01 I.R.B. 2022-01 297 2022-9 2022-02 I.R.B. 2022-02 310 2022-11 2022-03 I.R.B. 2022-03 449 2022-8 2022-04 I.R.B. 2022-04 451 2022-10 2022-06 I.R.B. 2022-06 473 2022-13 2022-06 I.R.B. 2022-06 477 2022-12 2022-07 I.R.B. 2022-07 494 2022-14 2022-07 I.R.B. 2022-07 502 2022-15 2022-13 I.R.B. 2022-13 908 2022-17 2022-13 I.R.B. 2022-13 930 2022-17 2022-13 I.R.B. 2022-13 933 2022-20 2022-14 I.R.B. 2022-14 945 2022-21 2022-16 I.R.B. 2022-16 1015 2022-23 2022-18 I.R.B. 2022-18 1052 2022-24 2022-20 I.R.B. 2022-20 1075 2022-22 2022-21 I.R.B. 2022-21 1098 Revenue Rulings: Article Issue Link Page 2022-1 2022-02 I.R.B. 2022-02 301 2022-2 2022-04 I.R.B. 2022-04 451 2022-3 2022-06 I.R.B. 2022-06 467 2022-4 2022-10 I.R.B. 2022-10 790 2022-5 2022-10 I.R.B. 2022-10 792 2022-6 2022-12 I.R.B. 2022-12 904 2022-7 2022-14 I.R.B. 2022-14 935 2022-8 2022-14 I.R.B. 2022-14 936 2022-9 2022-18 I.R.B. 2022-18 1041 2022-10 2022-23 I.R.B. 2022-23 1157 2022-11 2022-23 I.R.B. 2022-23 1159 Treasury Decisions: Article Issue Link Page 9959 2022-03 I.R.B. 2022-03 328 9961 2022-03 I.R.B. 2022-03 430 9960 2022-07 I.R.B. 2022-07 481 9962 2022-11 I.R.B. 2022-11 823 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2021. Finding List of Current Actions on Previously Published Items1 Bulletin 2022–26 How to get the Internal Revenue Bulletin INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.