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Internal Revenue Service › Disclosure Requirements › Partnerships

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

Cadwalader, Wickersham & Taft LLP on

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more

Levenfeld Pearlstein, LLC

‘Danger, Will Robinson’: The IRS Increases Scrutiny of Conservation Easements

Levenfeld Pearlstein, LLC on

Sometimes tax motives overwhelm philanthropic motives, which has often been the case with charitable deductions for so-called “conservation easements.” For years now, sponsors have offered up investments in partnerships,...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

Proskauer - Tax Talks on

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more

Kohrman Jackson & Krantz LLP

Artificial Intelligence Allows IRS to Increase Scrutiny of High-Earners & Partnerships

Kohrman Jackson & Krantz LLP on

The Internal Revenue Service (IRS) recently announced a renewed effort to ensure compliance with federal tax law, specifically focusing on high-income earners, partnerships, and large corporations. This additional scrutiny...more

Harris Beach Murtha PLLC

IRS Final Regulations Eliminate “Bottom Dollar” Guarantees

Harris Beach Murtha PLLC on

On October 9, 2019, the Internal Revenue Service (“IRS”) issued final regulations on the allocation of partnership recourse  liabilities that essentially eliminate the use of “bottom dollar” guarantees to increase a partner’s...more

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