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TREAS/IRS RIN: 1545-BN62 Publication ID: Fall 2016 
Title: ●Accounting Periods and Methods of Accounting; Advance Payments for Goods and Long-Term Contracts 
Abstract:

These proposed regulations provide guidance under section 451 regarding the  taxable year of inclusion of revenue that has been deferred from inclusion in gross income under section 1.451-5 of the Income Tax Regulations. If a taxpayer has deferred revenue from gross income inclusion under section 1.451-5, and a controlling interest of its stock is acquired by an unrelated corporation that writes down any part of the deferred revenue for financial purposes, the taxpayer must include in gross income the amount of the deferred revenue that is written down in the year of the write-down.

 
Agency: Department of the Treasury(TREAS)  Priority: Substantive, Nonsignificant 
RIN Status: First time published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage 
Major: No  Unfunded Mandates: No 
EO 13771 Designation: uncollected 
CFR Citation: 26 CFR 1.451-5   
Legal Authority: 26 U.S.C. 7805    26 U.S.C. 451   
Legal Deadline:  None
Timetable:
Action Date FR Cite
NPRM  12/00/2016 
Additional Information: REG-125136-16 Drafting attorney: Charles Gorham (202) 317-5091 Reviewing attorney: Christina Glendening (202) 317-4746 Treasury attorney: Christopher Call (202) 622-6865 CC:ITA
Regulatory Flexibility Analysis Required: No  Government Levels Affected: None 
Small Entities Affected: Businesses  Federalism: No 
Included in the Regulatory Plan: No 
RIN Data Printed in the FR: No 
Agency Contact:
Charles W. Gorham
Attorney
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW.,
Washington, DC 20224
Phone:202 317-7003
Fax:855 576-2336
Email: charles.w.gorham@irscounsel.treas.gov