INCOME TAX

REG–127203–15, page 918. Proposed regulations address transfers of appreciated property by United States persons (U.S. persons) to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied. The document also contains regulations under sections 197, 704, and 6038B that apply to certain transfers described in section 721. The regulations affect U.S. partners in domestic or foreign partnerships. The text of the proposed regulations is the same as temporary regulations published in TD 9814.

REG–137604–07, page 920. The proposed regulations reflect changes to the Code relating to the dependency exemption. The proposed regulations also make conforming changes relating to the definition of surviving spouse and the definition of head of household, the tax tables for individuals, the child and dependent care credit, the earned income credit, the standard deduction, joint tax returns, and taxpayer identification numbers for children placed for adoption. To make the earned income credit and the dependency exemption easier for taxpayers to claim, the proposed regulations change the IRS’s position regarding who may take the childless earned income credit and the source of support for certain payments originating as governmental payments. The proposed regulations also change the IRS’s position regarding the adjusted income of a taxpayer filing a joint return to be consistent with other Code sections that require the filing of a joint return.

Action On Decision 2017–01, page 868. Nonacquiescence to the holding that a limited partnership was not a farming syndicate because the sole shareholder of a limited partner S Corporation actively participated in the farming business.

Finding Lists begin on page ii.