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Accrual-Basis Taxpayer Cannot Take Bonuses into Account until Paid
Deloitte via BenefitsLink 
[Guidance Overview] Jan. 27, 2010
Excerpt: Further, the IRS pointed out that the 'all events' test cannot be satisfied earlier than when the 'economic performance' occurs. Because the employer's bonus plan required the employees to continue their service to the company until the date the bonuses were paid, the economic performance did not occur and the liability was not fixed until the date the bonuses were actually paid.
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