On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships:
In new proposed regulations, the IRS identified several...more
On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more
9/13/2023
/ Enforcement Actions ,
Estate Planning ,
Inflation Reduction Act (IRA) ,
Investment Management ,
IRS ,
Offshore Funds ,
Partnerships ,
Private Equity ,
TEFRA ,
Trustees ,
Wealth Tax
On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the...more