Adriana Lofaro Wirtz

Jan 14, 2025 | velaw.com | George Matthew Gerachis |Gary Huffman |Kathy Pakenham |Adriana Lofaro Wirtz

By George Gerachis, Gary Huffman, Kathy Pakenham, Adriana Wirtz, Stephen Josey, and Margaret Hill 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.” (Our prior coverage of the IRS’s guidance package aimed at related-party basis adjustment transactions can be found here and our prior coverage of the IRS’s large partnership...

Oct 9, 2023 | lexology.com | George Matthew Gerachis |Kathy Pakenham |Gary Huffman |Adriana Lofaro Wirtz |Ryan Carney |David Peck | +1 more

Key Takeaways: The Internal Revenue Service (“IRS” or “agency”) will be auditing 75 of the largest partnerships, including hedge funds, real estate investment partnerships, publicly traded partnerships, and law firms, in addition to conducting 500 compliance audits of partnerships across industries These audits will be heavily coordinated and will use data analytics, including Artificial Intelligence (“AI”) tools The agency has announced that it will “stand up” a new group to focus on audits...

Sep 27, 2023 | jdsupra.com | George Matthew Gerachis |Adriana Lofaro Wirtz |Kathy Pakenham

Large partnership audits are a cornerstone of the IRS’ revamped enforcement priorities. As part of its Large Partnership Compliance program, the agency recently announced that it is rolling out audits of 75 large partnerships (including hedge funds, real estate investment partnerships, publicly traded partnerships, and law firms) identified through its new Artificial Intelligence tools, with more to follow. Join us to learn how to prepare for and navigate this new breed of audit.