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TREAS/IRS | RIN: 1545-BH10 | Publication ID: Fall 2022 |
Title: Interest on Deferred Tax Liability for Contingent Payment Sales Under Section 453(A) | |
Abstract:
Taxpayers that dispose of certain property where at least 1 payment is to be received after the close of the taxable year in which the disposition occurs (installment sales) can account for the income from the disposition under the installment method in section 453. Under the installment method the taxpayer pays tax on installment sale income as installment payments are received, thus deferring some or all of the tax liability to a later year. For installment sales in excess of $150,000, section 453A requires taxpayers to pay interest on the deferred tax liability that results from the use of the installment method. These proposed regulations will provide rules under section 453(A)(c) to compute the interest on the deferred tax liability for installment sales involving contingent payments. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Long-Term Actions |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 U.S.C. 453(A)(c)(6) 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-137603-07 Drafter attorney: Amy J. Pfalzgraf (202) 317-7006 Reviewer attorney: Amy J. Pfalzgraf (202) 317-7006 Treasury attorney: N/A 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: Amy J. Pfalzgraf Branch Chief Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-7006 Email: amy.j.pfalzgraf@irscounsel.treas.gov |