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Acceleration of deferred revenue in M&As

Sec. 451(c) should be considered when structuring such M&A transactions — including special rules
relating to short tax years of 92 days or less.

Understanding the mechanics of FASB ASC Subtopic 740-10

FASB ASC Subtopic 740-10 requires that each tax position meet a more-likely-than-not test and that the tax benefits be correspondingly reduced if the result is not certain; it is important to understand the administrative issues and problems created by this requirement.