On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more
On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more
Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more
This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more
This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and partnership interests or...more
In Private Letter Ruling 202352011 (December 30, 2023), the taxpayer asked the IRS to determine the amount that it will realize in a property transaction. The taxpayer will receive the property in an arm’s length exchange...more
On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...more
Typically, when a participant receives annuity payments from a defined benefit pension plan where he or she has a basis in the benefit (what Code Section 72 calls an “investment in the contract”), a portion of the payment is...more
Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more
Income Tax Considerations of Estate Planning Are More Important Than Ever - Gifting assets during life will reduce the size of your taxable estate at death and, correspondingly, reduce your estate tax liability. But with...more