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 ...
In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally ...
WASHINGTON, D.C. — The Department of the Treasury and the Internal Revenue Service (IRS) have issued final regulations ...
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 ...
President Biden is putting forward new rules to go after wealthy tax cheats as the battle on how to tax the economy sizzles ahead of the election. The new rules target businesses designated as ...
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. But ...
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