Eversheds Sutherland Tax Reform Law Blog
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IRS to Issue Proposed Regulations on Market Discount

The IRS and Treasury Department have recently announced (Notice 2018-80) that they plan to issue guidance providing that market discount is not includible in income under section 451(b), which was added to the Code by the Tax Cuts and Jobs Act.  Under section 451(b), accrual method taxpayers generally must include an amount in gross income no later than when it is included in income in...