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Completed contract method

Percentage-of-completion method look-back interest isn’t eligible for netting

Percentage-of-completion method look-back interest isn’t eligible for netting

Program Manager Technical Advice 2015-016 In Program Manager Technical Advice, IRS has concluded that look-back interest that either the taxpayer owes IRS or IRS owes the taxpayer, at the conclusion of a contract accounted for under the percentage-of-completion method (PCM), is not eligible for interest netting, but that any underpayment/overpayment interest arising from look-back interest […]

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Fifth Circuit holds residential land developer couldn’t use completed contract method

Fifth Circuit holds residential land developer couldn’t use completed contract method

Howard Hughes Company, L.L.C. v. Comm. (CA 5 10/27/2015) 116 AFTR 2d ¶ 2015-5368 The Court of Appeals for the Fifth Circuit, affirming the Tax Court, has concluded that none of the taxpayers’ contracts were home construction contracts under Code Sec. 460(e), so they couldn’t account for them using the completed contract accounting method. Background. A […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney