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IRS and Treasury release Section 451 proposed regulations

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September 2019


The IRS and Treasury have released proposed regulations under Section 451(b) and separate proposed regulations under Section 451(c). The proposed regulations provide rules for accrual-method taxpayers on the timing of recognizing income under the all-events test and on deferring recognition of certain advance payments. PwC will publish a detailed analysis of the proposed regulations within the coming days.  PwC professionals will discuss the proposed regulations in an upcoming Tax Readiness series webcast. 

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Brad White

Specialized Tax Services Leader, PwC US

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