The Doctrine of Cash Equivalence states that the U.S. Federal income tax law treats certain non-cash payment transactions like cash payment transactions for federal income tax purposes.
The cash equivalence doctrine arose out of a need to determine whether certain items that were either actually or constructively received must be accrued as income.
A dispute over timing of income recognition for tax purposes may arise when the thing received is really not much more than a promise of payment, such as a promissory note or a bond.
[9] The United States Court of Appeals for the Fifth Circuit established the standard for applying the cash equivalence doctrine to promises of payment.
If either of these situations exist, a taxpayer must determine whether the item received is cash equivalence, using the six factors described in Cowden v. Commissioner.