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 ...

In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this ...

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 ...

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 ...

The IRS intends to close a tax loophole in several actions that agency leaders say could add over $50 billion to U.S. government coffers over 10 years. The Service announced Monday that it will ...

Monte Jackel of Jackel Tax Law discusses partnership taxation rules and the role they play in former President Trump’s ongoing IRS audit. This transcript has been edited for length and clarity. David ...

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.