IRS CCA: Changing Method of Accounting After Tax Reform (IRC §451)

An accrual method taxpayer’s present method of accounting for an item of gross income that’s impermissible under tax Code Section 451(b)(1)(C) is eligible to obtain automatic consent of the Commissioner to change its method of accounting to comply with Section 451(b)(1)(A) if the taxpayer satisfies all other conditions set forth in Revenue Procedure 2018-60, the Chief Counsel’s Office advised. Taxpayer sought relief because its present method of accounting became an impermissible method that didn’t comply with all events test of Section 451 after the 2017 tax act, Pub. L. No. 115-97, took effect. ...