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 ...

A partner’s tax basis in his partnership interest (referred to as “outside basis”) generally represents his economic investment in a partnership plus his share of the partnership’s liabilities. In ...

Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular ...

An IRS proposal to drop a Biden administration rule targeting basis-shifting strategies by complex partnerships is getting support from key stakeholders, as well as calls for further relief.

The Biden administration is ramping up new audit teams and regulations to collect some $50 billion in taxes over the next decade from business partnerships such as hedge funds, real estate investors ...

The Internal Revenue Service is targeting the use of basis shifting between related parties as a way for partnerships to avoid paying taxes, setting up a new unit within the Office of Chief Counsel to ...

The IRS issued final regulations (T.D. 10028) Friday that identify certain partnership related-party basis-shifting transactions and substantially similar transactions as transactions of interest ...

The IRS intends to close a tax loophole in several actions that agency leaders say could add over $50 billion to U.S. government coffers over 10 years. The Service announced Monday that it will ...

Yes. The deduction of a limited partner’s share of partnership losses is limited by the partnership basis, the at risk rules and the passive loss rules. Partnership basis. A partner may not deduct the ...

WASHINGTON, DC - JANUARY 31: U.S. President Donald Trump talks to reporters after signing an executive order, "Unleashing prosperity through deregulation," in the Oval Office on January 31, 2025 in ...