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Income set apart or made available is not constructively received if its actual receipt is subject to substantial restrictions. .
Original issue discount be reported when it is earned, regardless of the TP's accounting method. The interest earned is calculated by the effective interest rate method. .
→ don't do to U.S. savings bonds or to obligations with maturity date of one year or less from the date of issue. .
Series E → before 1980.
Series EE → after 1979 → Income from both is deferred until redeemed or mature. .
Both can be exchanged within one year of their maturity date for series HH bonds, interest can also be deferred. A cash basis TP can elect to include in gross income the annual incremental redemption value. When the TP elects to report the income annually, then he must do so to all such securities. .
Exceptions Applicable to Accrual Basis Taxpayers: .
Prepaid Income is taxed in the year of receipt. .
Deferral of advance payments for goods → can defer if the method of accounting for the sale is the same for tax and financial reporting purposes. .
Deferral of advance payment for services:.
→ defer adv, pmts. For services to be performed by the end of the year following the year of receipt. No deferral is allowed if the TP might be required to perform any services, under the agreement, after the tax year following the year of receipt of the advance payment. (does not apply to prepaid rent or prepaid interest) .
Income Services.
Services of a child: amounts earned form personal services must be included in the child's gross income. .
Income from property must be included in the gross income of the owner of the property.
Interest accrues daily. .
Gift of income producing property, the donor must recognize his/her share of the accrued income at the time it would have been recognized had the donor continued to own the property. .
If transfer is a sale, the transfer must recognize the accrued income at the time of the sale.