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Penalties Revenue Rulings

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

Vinson & Elkins LLP on

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

Proskauer - Tax Talks

IRS and Treasury Announce Withdrawal of Related Party Basis Shifting Regulations

Proskauer - Tax Talks on

On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain...more

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