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Final regulations on changes to income recognition rules; initial impressions

Final regulations, changes to income recognition rules

Final regulations under sections 451(b) and 451(c) addressing amendments made by the 2017 tax law (Pub. L. No. 115-97), or the legislation commonly referred to as the “Tax Cuts and Jobs Act” (TCJA), are published in today’s edition of the Federal Register.


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The final regulations adopted regulations that were proposed in September 2019, but with significant revisions to the proposed regulations. The final regulations include two major sections:

  • The first provides guidance regarding section 451(b), amending the “all events test” to require certain taxpayers to recognize income no later than the tax year in which the amount is included in revenue for financial accounting purposes.
  • The second provides guidance regarding section 451(c), and codifying the deferral method of accounting for certain advance payments. Section 451(c), as amended, largely codifies Rev. Proc. 2004-34 (with which many taxpayers are already familiar) but makes certain changes to those rules as well.

Read KPMG report that provides initial observations and a high-level summary of the final regulations: KPMG report: Final regulations on changes to income recognition rules; initial impressions [PDF 282 KB] (11 pages)

Note that the final regulations are complex and will likely take some time for taxpayers to properly implement.  

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