Accrual basis taxpayer using consulting company for credit application.

Tax years are 2020 and 2021.

Filed all paperwork in 2022.

Began receiving checks from IRS in 2023.

I know that the credits are to be used as wage reductions in the year that they apply to. However, they will not be paying the fee to the consultant until 2023. They are also receiving interest in addition to the credit amount. 

My thinking is that the fee payment should be a deduction in the year paid since, according to the agreement, they are not liable for the fee unless the credit actually was paid. Also, I believe the interest income paid by the IRS is taxable in the year of receipt.

Opinions?

Thanks in advance.