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Tax Returns Compliance Disclosure Requirements

Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

Vinson & Elkins LLP on

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

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