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 ...
On Jan. 14, 2025, the Treasury Department issued final regulations designating certain related-party partnership basis shifting transactions as “transactions of interest.” Although this designation ...
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 ...
On June 17, 2024, the IRS released Notice 2024-54, which states that the IRS and the Treasury Department intend to issue proposed regulations relating to partnership basis adjustments resulting from ...
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