To embed, copy and paste the code into your website or blog: Just in time to add to your holiday reading list, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations under sections 451(b) and 451(c) of the Code addressing income recognition and the treatment of advance payments (Final Regulations). Under the Tax Cuts and Jobs Act 2 (TCJA), Congress amended section 451(b) and added section 451(c) to the Internal Revenue Code, dramatically altering the historic standard of income recognition, 3 and also codified a longstanding method of accounting allowing income deferral for advance payments. 4 Nearly two years later, on September 9, 2019, the IRS issued proposed regulations under section 451(b) and section 451(c) (Proposed Regulations).