WebAug 1, 2024 · While the gross receipts test is fairly straightforward, Sec. 448(c)(2) requires all persons treated as a single employer under Sec. 52(a) or (b) or Sec. 414(m) or (o) to be treated as one person for purposes of the gross receipts test; this potentially … WebInternal Revenue Code Section 448 Limitation on use of cash method of accounting. (a) General rule. Except as otherwise provided in this section, in the case of a— (1) C corporation, (2) partnership which has a C corporation as a partner, or (3) tax shelter, …

Internal Revenue Bulletin: 2024-48 Internal Revenue Service - IRS

WebTo determine whether the section 448(c) gross receipts test is met, the aggregation rules under section 448(c)(2) apply. Generally, the aggregation rules combine the gross receipts of multiple taxpayers if they are treated as a single employer under the controlled group … cheap airfare to thailand

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WebAug 5, 2024 · After the TCJA, Internal Revenue Code (IRC) Section 460 now refers to IRC §448(c) for purposes of determining how to calculate gross receipts. 1. Similar to the pre-TCJA gross receipts test, gross receipts means the total amount of receipts (reduced by returns and allowances), as determined under the taxpayer’s method of accounting, … WebMay 1, 2024 · Specifically, Sec. 448(c)(2) requires the aggregation of gross receipts for entities treated as a single employer for purposes of the work opportunity tax credit in Secs. 52(a) and 52(b) or under the qualified plan rules relating to affiliated service … WebFor gross receipts testing purposes, taxpayers should be mindful of whether the aggregation rule of Section 448(c)(2) applies to combine gross receipts of another entity. The aggregation rule provides that all taxpayers treated as a single employer under Section 52(a) or (b), or Section 414(m) or (o), will be treated as a single taxpayer. cheap air filter