News & Analysis as of

Corporate Taxes Accounting Methods

Miller Canfield

Be Wary of Relying on Recent Tax Decisions for Recent Transactions

Miller Canfield on

At issue in Continuing Life Thousand Oaks, LLC. v. Commissioner, affirmed May 21, 2024, was the year of inclusion in gross income of an income item. The disputed years were 2008, 2009, and 2010 -- taxable years that preceded...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Barnea Jaffa Lande & Co.

Reporting Methods – “Accrual Basis” or “Cash Basis”

The district court recently ruled that when determining a business’s correct reporting method to the Israel Tax Authority (ITA)—on an accrual or a cash basis—it is insufficient to examine the technical question of a...more

Eversheds Sutherland (US) LLP

A Timely Update: The IRS and Treasury release Rev. Proc. 2022-14 updating list of automatic accounting method changes

Section 446(e) requires a taxpayer to obtain IRS consent prior to changing its accounting method. A change in method of accounting may include either a change in an overall plan of accounting for gross income or deductions...more

Eversheds Sutherland (US) LLP

Last minute addition to your summer reading list: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451...

On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more

Eversheds Sutherland (US) LLP

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

Eversheds Sutherland (US) LLP

IRS Releases Updated Automatic Changes in Methods of Accounting List

On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more

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