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 German holding company and a partnership both have zero basis in a $610 million promissory note contributed to one of the holding company’s subsidiaries, the US Tax Court held Monday, granting the ...

The Biden administration said large partnerships were illegally avoiding hundreds of billions in taxes. Trump says they shouldn’t have to report the transactions.

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 ...

The American Institute of CPAs sent a comment letter to the Treasury Department and the Internal Revenue Service objecting to their guidance around basis-shifting transactions involving partnerships ...

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 ...

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.

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 ...

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 ...

A partnership whose sole asset is all the stock of a corporation offers opportunities but with potential pitfalls.

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 ...