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A Giant Eagle rematch? IRS Chief Counsel reiterates its disagreement with Third Circuit s interpretation of all-events test | Eversheds Sutherland (US) LLP

A Giant Eagle rematch? IRS Chief Counsel reiterates its disagreement with Third Circuit s interpretation of all-events test | Eversheds Sutherland (US) LLP
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Christmas comes early for taxpayer seeking to include construction service costs as part of bonus depreciation eligible investment upon property acquisition | Eversheds Sutherland (US) LLP

In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible.

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State of play: A May methods update | Eversheds Sutherland (US) LLP

To embed, copy and paste the code into your website or blog: At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and practitioners on the status of guidance projects, and offered clarification regarding certain recent legislative proposals. IT&A leadership acknowledged that while during the onboarding of a new administration the guidance process tends to slow, the Biden Administration came in quickly with experienced leadership, ready to work and “firing on all cylinders.” This alert walks through several of the tax accounting and federal updates the government attorneys provided, insight with respect to future pieces of guidance and legislative proposals, and what taxpayers should anticipate in coming months.

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IRS fails to realize certain income recognition issues in final section 451 regulations | Eversheds Sutherland (US) LLP

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).

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