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Recognition is mostly a matter of timing; the issue is not whether income or loss is taken into account, but when. The time of recognition may matter for a number of reasons, including the time value of money and the section 1211(b) limitation on capital losses in a single year. [3]
This violates traditional accrual method recognition of income and is an exception to the all-events test because the right to income is not yet fixed. The taxpayer has not yet performed services allowing for the collection of income but through Revenue Ruling the IRS has determined that recognition of income is proper because cash is in hand. 2.
A dispute over timing of income recognition for tax purposes may arise when the thing received is really not much more than a promise of payment, such as a promissory note or a bond. If mere promises to pay were considered cash equivalents, then there would be little difference between the cash and accrual methods for tax purposes. [9]
Realization, for U.S. Federal income tax purposes, is a requirement in determining what must be included as income subject to taxation. It should not be confused with the separate concept of Recognition (tax).
The Internal Revenue Code governs the application of tax accounting. Section 446 sets the basic rules for tax accounting. Tax accounting under section 446(a) emphasizes consistency for a tax accounting method with references to the applied financial accounting to determine the proper method. The taxpayer must choose a tax accounting method ...
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. [1] A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid. [2] Unlike actual receipt, constructive receipt does ...
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