
Section 467 Rental Agreements: Stepped, Prepaid, and Deferred Rent Under the Tax Code's Anti-Abuse Rule
Section 467 forces accrual accounting and imputed interest on commercial leases over $250,000 with stepped, prepaid, or deferred rent — overriding cash-basis treatment, recharacterizing part of every rent payment as a deemed loan between landlord and tenant, and creating Schedule M-1 book-tax differences from ASC 842 straight-line rent.










