Instructions For Form 8697 Draft (Rev. December 2011) - Interest Computation Under The Look-Back Method For Completed Long-Term Contracts

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Instructions for Form 8697
Department of the Treasury
Internal Revenue Service
(Rev. December 2011)
Interest Computation Under the Look-Back Method for Completed Long-Term
Contracts
Section references are to the Internal
long-term contract entered into after
Schedule K-1 the information you need
February 28, 1986, that you accounted
to complete this form.
Revenue Code unless otherwise noted.
for using either the percentage of
General Instructions
Mid-Contract Change in
completion method or the percentage of
Taxpayer
completion-capitalized cost method for
What’s New
Federal income tax purposes. You also
If prior to the completion of a long-term
must file Form 8697 for any tax year,
contract accounted for using the
Form 8697 has been revised to
subsequent to the year of completion,
percentage of completion method or the
provide a column for the filing year. The
in which the contract price or contract
percentage of completion capitalized
cumulative effect of applying the
costs are adjusted for one or more of
cost method, there is a transaction that
look-back is taken into account
these long-term contracts from a prior
makes another taxpayer responsible for
beginning in the filing year even though
year.
accounting for income from the same
look-back interest is not computed for
contract, the taxpayer responsible for
that year. Income is hypothetically
Pass-Through Entities
filing look-back interest depends on
reallocated to or from the filing year or
whether the ownership change is due
from the redetermination years.
A pass-through entity (partnership, S
to a constructive completion transaction
Look-back does not create or decrease
corporation, or trust) that is not closely
or a step-in-the shoes transaction. For
income, it only hypothetically changes
held must apply the look-back method
guidance regarding these transactions,
the tax year of recognition.
at the entity level to any contract for
see Regulations 1.460-4(g). In the case
A second signature line has been
which at least 95% of the gross income
of constructive completion transactions,
added for the spouse’s signature if a
is from U.S. sources. A pass-through
the old taxpayer applies the look-back
joint tax return was filed.
entity is considered closely held if, at
method to the pre-transaction years
The tax rates used for the interest
any time during any tax year for which
and the new taxpayer applies the
computation have changed. See the
there is income under the contract,
look-back method to the
instructions for line 2, later.
50% or more (by value) of the
post-transaction years. In the case of
The IRS has created a page on
beneficial interests in the entity is held
step-in-the-shoes transactions, the new
IRS.gov for information about Form
(directly or indirectly) by or for five or
taxpayer applies the look-back method
fewer persons. For this purpose, rules
8697 and its instructions, at
to both the pre and post transaction
gov/form8697.
Information about any
similar to the constructive ownership
years. See Regulations section
future developments affecting Form
rules of section 1563(e) apply. For a
1.460-6(g) for additional guidance.
8697 (such as legislation enacted after
mid-contract change in taxpayer
we release it) will be posted on that
resulting in the conversion of a C
Exception for Certain
page.
corporation into an S corporation, the
Construction Contracts
look-back method is applied at the
Purpose of Form
The look-back method does not apply
entity level with respect to contracts
to the regular taxable income from:
entered into prior to the pre-transaction
Use Form 8697 to figure the interest
Any home construction contract (as
years regardless of whether the S
due or to be refunded under the
defined in section 460(e)(6)(A)) or
corporation is considered closely held.
look-back method of section 460(b)(2)
Any other construction contract
See the section discussing
on certain long-term contracts that are
entered into by a taxpayer: (a) who
Mid-Contract Change in Taxpayer.
accounted for under either the
estimates the contract will be
percentage of completion method or the
completed within 2 years from the date
If you are an owner of an interest in
percentage of completion-capitalized
the contract begins and (b) whose
a pass-through entity for every year in
cost method. For guidance concerning
average annual gross receipts for the 3
which a long-term contract was being
these methods, see Regulations
tax years preceding the tax year in
accounted for under the percentage of
1.460-4. For details and computational
which the contract is entered into do
completion method or the percentage of
examples illustrating the use of the
not exceed $10 million. See section
completion-capitalized cost method and
look-back method, see Regulations
460(e).
the pass-through entity is not subject to
section 1.460-6.
the look-back method at the entity level,
However, the look-back method
you must file this form for your tax year
does apply to the alternative minimum
Who Must File
that ends with or includes the end of
taxable income from any such contract
the entity’s tax year in which the
that must be accounted for using the
General Rule
contract was completed or adjusted in a
percentage of completion method for
You must file Form 8697 for each tax
post-completion tax year. The
alternative minimum tax purposes. See
year in which you completed a
pass-through entity will provide on
section 56(a)(3) for details.
Jan 05, 2012
Cat. No. 10703K

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