Internal Revenue Code (IRC) section
1.460 provides rules for determining whether a contract for the
manufacture, building, installation, or construction of property is
a long-term contract under section 460 and what activities must be
accounted for as a single long-term contract. Specific rules for
long-term manufacturing and construction contracts are provided in
§§ 1.460-2 and 1.460-3, respectively. A taxpayer generally must
determine the income from a long-term contract using the
percentage-of-completion method described in § 1.460-4(b) (PCM) and
the cost allocation rules described in § 1.460-5(b) or (c). In
addition, after a contract subject to the PCM is completed, a
taxpayer generally must apply the look-back method described in §
1.460-6 to determine the amount of interest owed on any
hypothetical underpayment of tax, or earned on any hypothetical
overpayment of tax, attributable to accounting for the long-term
contract under the PCM. TD 8929 requires that information be
collected in order to notify the Commissioner of a taxpayer's
decision to sever or aggregate one or more long- term contracts
under the regulations. The statement is needed so the Commissioner
can determine whether the taxpayer properly severed or aggregated
its contract(s). The regulations affect any taxpayer that
manufactures or constructs property under long-term contracts. TD
8775 and requires taxpayers to attach a notification statement to
their returns when they make the election and TD 8995 is required
to enable taxpayers to make look-back computations when the income
from a long-term contract has been previously reported by another
taxpayer.
US Code:
26
USC 7805 Name of Law: Rules and regulations.
US Code: 26
USC 460 Name of Law: Special rules for long-term contracts
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