January 2018 - The Tax Adviser

Implementation of certain parts of Sec. 871(m) regs. delayed a year

U.S. parent’s CFCs held U.S. property under Sec. 956 as result of intercompany transactions

Court rules mortgage broker is not real estate professional, passive activity rules apply

IRS will not acquiesce to ruling on non-safe-harbor reverse Sec. 1031 exchange

Income from receipt of carbon sequestration credits relating to timberlands is qualifying REIT income

Safe harbor eliminates need for private letter ruling for some REIT and RIC distributions of stock and cash

IRS withdraws portions of Subchapter C nonrecognition rules

IRS holds investment transaction is sale of refined coal tax credits

Individual entitled to bad debt deduction for loss on loans to business

Tax Court holds microcaptive insurance company was not a bona fide insurer

Inflation adjustments and tax tables for 2018 tax returns are issued

IRS announces 2018 pension plan contribution limits

Taxpayers must comply with health care reporting requirements on 2017 returns

2018 wage base for Social Security taxes will increase slightly this year

Proposed regulations would allow Sec. 754 election without partner’s signature

2017 Arthur J. Dixon Memorial Award

Transcript of account issued by the IRS

Items and factors to consider in setting reasonable compensation

Form 8879: Requirements, possible problems, and best practices for practitioners

When to use a tax-free reorganization

Pilot grounded on foreign income exclusion

Lack of economic substance dooms loss deductions