Clarification on TCJA and the Cash Method

Last Friday, the Service released CCA 202002013, which clarifies the impact of the TCJA on cash basis taxpayers. The issue is fairly simple. In the TCJA, Congress modified certain rules in Code section 451. This Code section provides the general rules to determine when taxpayers must include an item in gross income. Congress made substantial modifications to the rules under this section for accrual basis taxpayers. The question the Service addressed was whether this also affected when cash basis taxpayers take into account income. The answer was "no".

While this may seem like a straightforward issue, many practitioners have been confused by these new provisions. This has been especially true when the taxpayer has an AFS and uses accrual for book and cash for tax.