Recognition of income when affiliates are used to provide services.

The Tax AdviserVol. 23 Nbr. 7, July 1992

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Summary


The IRS policy prohibiting advance payment recognition deferment when services contracted for are subcontracted or performed by an affiliate is too restrictive. Generally, those payments are counted when they are received, but contracts that are accounted on an accrual basis that permits deferral to the next year if performed by the taxpayer. If the taxpayer accepts the risks, the potential for abuse is negligible.

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Extract


Recognition of income when affiliates are used to provide services.

Does the use of affiliates or independent contractors to provide services preclude the ability of a taxpayer to defer recognition of advance payments under Rev. Proc. 71-21? ...

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