Sarah Rizzo

Jun 25, 2024 | lexology.com | Trevor Allen |Edward Gonzalez |Kathleen Gregor |Sarah Rizzo |Jeff Romero |Paul Schockett | +1 more

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several transactions as “transactions of interest,” which would require taxpayers and material advisors to report such transactions to the IRS.1 Notice 2024-54 describes two sets of forthcoming proposed regulations that would have the effect of (i) suspending the basis-adjustment benefits of...

May 11, 2023 | lexology.com | Nickolas Gianou |Nathan Giesselman |Kathleen Gregor |Shalom Huber |Sarah Rizzo |Paul Schockett | +2 more

On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the benefit of an operating partnership in a tiered partnership context. ES NPA Holding LLC v. Commissioner, T.C. Memo 2023-55 (May 3, 2023).