Learn to identify options and methods to limit or defer the recognition of income via certain provisions contained within Section 451 regulations.
Income and its recognition is the starting point for all for-profit entities as they determine their ultimate tax liability for a given tax year. The IRS regulations under Section 451(b) and (c), applicable for 2021 and future tax years, provide taxpayers with guidance related to the timing of income inclusion generally as well as the treatment of advance payments for goods, services, and certain other items. The final Section 451 regulations include new concepts and optional methods with respect to income recognition, which requires taxpayers to have a detailed understanding of their specific facts to determine how such rules apply to them. In addition, the final Section 451 regulations include certain provisions that may provide opportunities to limit the amount of income recognized in a given tax year, which taxpayers should consider as part of their overall implementation of the final regulations.
This course will provide an overview of and guidance on the final Section 451 regulations. The material will explore opportunities to limit income acceleration and discuss in detail the procedural guidance in place to implement the final Section 451 regulations.
Agenda
Faculty
Sam Weiler
Ernst & Young LLP
- Principal in Ernst & Young LLP’s National Tax – Accounting Methods, Periods, and Credits Group
- Primarily provides federal tax advisory services on capitalization and cost recovery items and issues, the timing provisions governing income and expense recognition, income exclusion provisions of the Internal Revenue Code, leasing, and like-kind exchange issues, as well as Internal Revenue Service procedures regarding the application of accounting methods and changes in accounting methods and periods
- Frequent speaker on various tax accounting topics and currently serves as a contributor/editor of the Bloomberg Tax Portfolio, Depreciation: MACRS and ACRS, No. 531; the Bloomberg Tax Portfolio, First-Year Expensing and Additional Depreciation, No. 532; and the Wolters Kluwer/CCH U.S. Master Depreciation Guide
- Member of the American Bar Association and its Tax Section, where he is the former Chair of the Capital Recovery and Leasing Committee and was previously named a John S. Nolan Fellow
- J.D. degree, The Ohio State University Moritz College of Law; M.S.A. and B.B.A. degrees, Ohio University
Alison Jones
Ernst & Young LLP
- Principal in Ernst & Young LLP’s Accounting Methods, Periods, and Credits Group
- Specializes in federal tax accounting method matters, including the accrual of income and deductions, capitalization, depreciation issues, and accounting method change requests
- Over the past several years, she has worked with an interdisciplinary team focused on the tax considerations of the new FASB/IASB Revenue Recognition Standard as well as the Tax Cuts and Jobs Act changes to the tax income recognition rules
- Worked with a variety of public and private clients in the manufacturing, distribution, retail, financial services, health care, oil and gas, utilities, and telecommunications industries and currently serves as EY’s Americas Tax Director for Engineering and Construction
- Frequent speaker at ABA and TEI events and served as an adjunct professor in the L.L.M. program at Georgetown University for almost a decade
- Licensed in the state of Texas and is a member of the American Bar Association Tax Section and a past vice-chair of the Capital Recovery and Leasing Subcommittee
- J.D. degree and B.A. degree in economics, University of Texas
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