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...