Time when economic performance occurs
Except as provided in regulations prescribed by the Secretary, the time when economic performance occurs shall be determined under the following principles:
(A) Services and property provided to the taxpayer If the liability of the taxpayer arises out of— (i) the providing of services to the taxpayer by another person, economic performance occurs as such person provides such services, (ii) the providing of property to the taxpayer by another person, economic performance occurs as the person provides such property, or (iii) the use of property by the taxpayer, economic performance occurs as the taxpayer uses such property.
(B) Services and property provided by the taxpayer If the liability of the taxpayer requires the taxpayer to provide property or services, economic performance occurs as the taxpayer provides such property or services.
(C) Workers compensation and tort liabilities of the taxpayer If the liability of the taxpayer requires a payment to another person and— (i) arises under any workers compensation act, or (ii) arises out of any tort, economic performance occurs as the payments to such person are made. Subparagraphs (A) and (B) shall not apply to any liability described in the preceding sentence.
(D) Other items In the case of any other liability of the taxpayer, economic performance occurs at the time determined under regulations prescribed by the Secretary.
(A)Services and property provided to the taxpayer#
If the liability of the taxpayer arises out of—
(i) the providing of services to the taxpayer by another person, economic performance occurs as such person provides such services,
(ii) the providing of property to the taxpayer by another person, economic performance occurs as the person provides such property, or
(iii) the use of property by the taxpayer, economic performance occurs as the taxpayer uses such property.
(A)(i)#
the providing of services to the taxpayer by another person, economic performance occurs as such person provides such services,
(A)(ii)#
the providing of property to the taxpayer by another person, economic performance occurs as the person provides such property, or
(A)(iii)#
the use of property by the taxpayer, economic performance occurs as the taxpayer uses such property.
(B)Services and property provided by the taxpayer#
If the liability of the taxpayer requires the taxpayer to provide property or services, economic performance occurs as the taxpayer provides such property or services.
(C)Workers compensation and tort liabilities of the taxpayer#
If the liability of the taxpayer requires a payment to another person and—
(i) arises under any workers compensation act, or
(ii) arises out of any tort,
economic performance occurs as the payments to such person are made. Subparagraphs (A) and (B) shall not apply to any liability described in the preceding sentence.
(C)(i)#
arises under any workers compensation act, or
(C)(ii)#
arises out of any tort,
(D)Other items#
In the case of any other liability of the taxpayer, economic performance occurs at the time determined under regulations prescribed by the Secretary.