The IRS has proposed regulations on the “tax year of income” inclusion for certain accrual method taxpayers. The proposed regs reflect changes to Sec. 451(b) made by the Tax Cuts and Jobs Act. They amended the section to provide that, for accrual-method taxpayers, the “all events” test for any gross income item isn’t treated as met any later than when the item is included in revenue for financial accounting purposes on an applicable financial statement (AFS) or other IRS-specified financial statements. The amendments didn’t change the time for when income, subject to the test, is taken into income for accrual method taxpayers with no AFS or other specified financial statement.
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