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Proposed regulations interpret the all-events test under Section 451(b)

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September 2019


The IRS and Treasury have released long-awaited proposed regulations implementing Sections 451(b) and 451(c), added by the 2017 tax reform act, and Rev. Proc. 2019-37, which provides procedures for a taxpayer to change its method of accounting to comply with the amendments to Section 451, including the proposed regulations.  This Insight discusses the Section 451(b) proposed regulations.  A forthcoming Insight will discuss the Section 451(c) proposed regulations and Rev. Proc. 2019-37

PwC professionals will discuss the proposed regulations in a Tax Readiness series webcast on Thursday, September 26, 2019, at 1 PM EDT.  Registration details for the webcast are available here.

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The takeaway

The issuance of the proposed regulations provides needed clarity for Section 451(b) rules that apply for tax years beginning in 2018.  Until final regulations are issued, taxpayers may rely on the proposed regulations (other than certain specified fee rules), or may look to existing authorities and reasonable interpretations of Section 451(b).

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Rebecca Lee

Principal, International Tax Services, PwC US

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