In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more
9/4/2025
/ Audits ,
Economic Substance Doctrine ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Revenue Rulings ,
Tax Audits ,
Tax Avoidance ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Treasury Regulations ,
U.S. Treasury
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
1/14/2025
/ Compliance ,
Congressional Review Act ,
Disclosure Requirements ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Planning ,
Tax Returns ,
Taxation ,
U.S. Treasury