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TREAS/IRS | RIN: 1545-BO78 | Publication ID: Spring 2018 |
Title: ●Guidance on New Section 451(c) | |
Abstract:
Section 451 generally governs the timing of income and provides that any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period. Generally, under 451(c), a deferral is permitted to the extent that the advance payment received is not due, paid, earned, or recognized as revenue for an applicable financial statement. Any remaining portion of such advance payment is recognized in gross income in the taxable year following the taxable year in which such payment is received. Section 451(c) also codifies much of the treatment of advance payments under Rev. Proc. 2004-34 and permits the allocation of the transaction price to performance obligations if consistent with applicable financial statements. |
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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: Undetermined | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805(a) 26 U.S.C. 451(c) (revision) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-104554-18 Drafter attorney: Peter E. Ford (202) 317-4878 Reviewer attorney: David M. Christensen (202) 317-4861 Treasury attorney: Christopher Call (202) 317-6865 CC:ITA | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Peter E. Ford Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-4878 Fax:202 317-4883 Email: peter.e.ford@irscounsel.treas.gov |