IRS issues penalty relief guidance for eligible taxpayers

November 2022

In brief

The IRS on November 16 issued Rev. Proc. 2022-39, setting forth special procedures for eligible large corporate and partnership taxpayers who are regularly selected for audit and have been selected for examination. The guidance allows eligible taxpayers to file a qualified amended tax return to reflect additional tax due or make adequate disclosure with respect to an item or a position on a previously filed return to avoid imposition of accuracy-related penalties. 

Taxpayers selected for examination under the Large Corporate Compliance (LCC) or the Large Partnership Compliance (LPC) program will be notified by the IRS if they are eligible taxpayers under Rev. Proc. 2022-39. The revenue procedure, which obsoletes and replaces Rev. Proc. 94-69, is effective for examinations of eligible taxpayers that begin after November 16, 2022.  

Action item: Taxpayers should analyze whether they qualify for the relief provided under Rev. Proc. 2022-39 or need to make additional filings/disclosures to the IRS to obtain penalty relief.

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Ed Geils

Ed Geils

Global and US Tax Knowledge Management Leader, PwC US

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