New rules on advance-payment income

September 11, 2019

Treasury recently issued two sets of proposed regulations that provide new rules on how taxpayers treat income from advance payments under new book-tax conformity rules.

One set of proposed regulations governs the timing of inclusion under Sec. 451(c) of advance payments for goods, services and other items.

The other set covers Sec. 451(b), which requires taxpayers that use the accrual method and have an applicable financial statement (AFS) to recognize income when the all-events test is met or when the item of income is included in revenue in its AFS (the AFS income inclusion rule).

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