The Tax Cuts and Jobs Act (TCJA) changed certain rules for accrual-method taxpayers. Previously, taxpayers who used the accrual-method generally needed to include income in the year in which all events had occurred that fixed the right to receive income and the amount could be determined with reasonable accuracy, the “all-events test”.
TCJA revised Section 451 so that, in general, for accrual-method taxpayers that have applicable financial statements, the “all events test” is met for an item of gross income no later than the taxable year in which such income is taken into account as revenue in its AFS. See Comparison of changes to rules for taxable year of inclusion under TCJA and Revenue Procedure 2018-60 for more information.
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