Notice Confirms Business as Usual for Taxpayers with Advance Payments

The IRS issued Notice 2018-35 on April 13, which permits taxpayers to continue to rely on Rev. Proc. 2004-34 for the treatment of advance payments under Section 451.  According to the Notice, the IRS will not challenge taxpayers’ use of the current guidance that provides for the limited deferral of advance payments. Additionally, the Notice requests comments with suggestions on Section 451 guidance, including: the applicability of Rev. Prov. 2004-34; whether the definition of “advance payments” should be expanded; and the possibility of expanding the rules under section 451(c), which allows for a one-year deferral on recognition.

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Read more: Much ado about nothing – IRS provides advance payments guidance with release of Notice 2018-35

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