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Final regulations under section 451 help taxpayers compute revenue Don Reiris, John Suttora and Caleb Cordonnier

By: Reiris, Don.
Contributor(s): Suttora, John | Cordonnier, Caleb.
Material type: ArticleArticleSubject(s): PLANIFICACION FISCAL | CONTRIBUYENTES | BENEFICIOS | LEGISLACION | INGRESOS FISCALES | ESTADOS UNIDOS In: Journal of Taxation of Investments v. 39, n. 2, Winter 2022, p. 3-22Summary: The final revenue recognition regulations under Internal Revenue Code Section 451 (effective for tax years beginning on or after January 1, 2021, with early implementation options), along with the companion procedural guidance, provide both tax planning opportunities and implementation hurdles for taxpayers. The authors explain the new rules and note the issues taxpayers will need to address to determine how to properly apply the new rules to their particular situations, balancing potential tax benefits against administrative complexity.
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The final revenue recognition regulations under Internal Revenue Code Section 451 (effective for tax years beginning on or after January 1, 2021, with early implementation options), along with the companion procedural guidance, provide both tax planning opportunities and implementation hurdles for taxpayers. The authors explain the new rules and note the issues taxpayers will need to address to determine how to properly apply the new rules to their particular situations, balancing potential tax benefits against administrative complexity.

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