On Jan. 14, 2025, the Treasury Department issued final regulations designating certain related-party partnership basis shifting transactions as “transactions of interest.” Although this designation ...
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the ...
The IRS and Treasury have now finalized regulations that require partnerships to disclose information about certain transactions involving distributions and transfers of partnership interests and ...
Yes. The deduction of a limited partner’s share of partnership losses is limited by the partnership basis, the at risk rules and the passive loss rules. Partnership basis. A partner may not deduct the ...
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 ...
WASHINGTON, DC - JANUARY 31: U.S. President Donald Trump talks to reporters after signing an executive order, "Unleashing prosperity through deregulation," in the Oval Office on January 31, 2025 in ...
The Tax Court has previously held that a partner who contributes his own note to a partnership in exchange for a partnership interest takes no basis in the interest and their capital account is not ...
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.
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