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 opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more
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