News & Analysis as of

U.S. Treasury Partnerships Tax Basis

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

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

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

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

Holland & Knight LLP

IRS Cracking Down on "Basis-Shifting" in Related-Party Partnership Transactions

Holland & Knight LLP on

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

Nutter McClennen & Fish LLP

Partnership Transactions and Bonus Depreciation: A Narrow Path

The recently issued bonus depreciation regulations should influence – but not control – how we structure certain partnership contributions and distributions. These transactions include partnership mergers and divisions....more

Blank Rome LLP

Anticipated IRS Regulations May Impact Discounts On Intra-Family Transfers of Closely Held Business Interests

Blank Rome LLP on

Action Item: It is anticipated that Treasury will soon issue new regulations that will affect the valuation discounts applicable to intra-family transfers of interests in closely held entities. It may be advisable to review...more

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