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TREAS/IRS RIN: 1545-BH10 Publication ID: Fall 2023 
Title: Interest on Deferred Tax Liability for Contingent Payment Sales Under Section 453A 

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 453A(c) to compute the interest on the deferred tax liability for installment sales involving contingent payments.

Agency: Department of the Treasury(TREAS)  Priority: Substantive, Nonsignificant 
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage 
Major: No  Unfunded Mandates: No 
CFR Citation: 26 CFR 1   
Legal Authority: 26 U.S.C. 453A(c)(6)    26 U.S.C. 7805   
Legal Deadline:  None
Action Date FR Cite
NPRM  06/00/2024 
Additional Information: REG-137603-07 Drafter attorney: Shareen Pflanz (202) 317-7006 Reviewer attorney: Shareen Pflanz (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:
Shareen Pflanz
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW,
Washington, DC 20224
Phone:202 317-7006
Fax:202 317-4743