INCOME TAX

Action On Decision 2017–06, page 194. Nonacquiescence relating to the holding that a taxpayer’s sale and acquisition of business property qualifies as a like-kind exchange under I.R.C. § 1031 even though 17 months before the purported exchange, an accommodating party facilitating the transaction acquired title to the replacement property and the taxpayer acquired the benefits and burdens of ownership of the property.

T.D. 9822, page 195. These final regulations provide relief to victims of domestic abuse and spousal abandonment from the requirement that married taxpayers file joint returns to obtain a premium tax credit (PTC). The regulations also address the allocation of certain amounts for computing the PTC and reconciling advance payments of the PTC with the allowable PTC, and rules for self-employed taxpayers claiming both a PTC and a § 162(l) deduction for health insurance expenses.

Notice 2017–36, page 208. This notice announces that the Department of the Treasury and the Internal Revenue Service intend to amend Treas. Reg. § 1.385–2 (the “Documentation Regulations”) to apply only to interests issued or deemed issued on or after January 1, 2019. This amendment has the effect of delaying the application of the Documentation Regulations by 12 months. The notice also requests comments concerning whether the proposed amendment and delay of the application of the Documentation Regulations affords adequate time for taxpayers to develop any necessary systems or processes to comply with the Documentation Regulations.

Finding Lists begin on page ii.