On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended ...

When you form a small business by creating a partnership, you and your partners contribute assets to the new company. This is the basis for each partner's interest in the company. Each partner forms a ...

The Internal Revenue Service has released a set of proposed regulations to prevent abuses of the partnership basis adjustment rules, disallowing partnership loss transfers to avoid some of the abuses ...

The American Institute of CPAs sent a comment letter to the Treasury Department and the Internal Revenue Service objecting to their guidance around basis-shifting transactions involving partnerships ...

The Internal Revenue Service is targeting the use of basis shifting between related parties as a way for partnerships to avoid paying taxes, setting up a new unit within the Office of Chief Counsel to ...

The Internal Revenue Service and Treasury Department launched a new initiative Monday aimed at closing a significant tax loophole often used by the super wealthy. The IRS said ending "partnership ...

Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular ...

An IRS proposal to drop a Biden administration rule targeting basis-shifting strategies by complex partnerships is getting support from key stakeholders, as well as calls for further relief.