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Part I Section 461.–General Rule for Taxable Year of …

Part I Section 461. general Rule for Taxable year of Deduction 26 CFR : general rule for Taxable year of deduction. (Also 404) Rev. Rul. 2007-12 ISSUE If the all events test and recurring item exception of 461 of the Internal Revenue Code are otherwise met, may an accrual method taxpayer treat its Federal Insurance Contributions Act (FICA) and Federal Unemployment Tax Act (FUTA) tax liability as incurred in year 1 if the compensation to which the tax liability relates is deferred compensation that is deductible under 404 in year 2?

4 economic performance. Under the recurring item exception, a liability is treated as incurred for a taxable year if: (i) at the end of the taxable year, all events have occurred

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