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 ...

The IRS on Wednesday issued proposed regulations providing guidance on the application of Sec. 704(c)(1)(C) added by the American Jobs Creation Act of 2004, P.L. 108-357 (AJCA), and the amendments to ...

The IRS has released a set of proposed regulations to prevent abuses of the partnership basis adjustment rules, disallow partnership loss transfers and avoid some of the abuses uncovered by the Enron ...

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 ...

In a taxpayer-friendly development, the IRS on Wednesday issued proposed regulations that would eliminate the regulations’ requirement that a partnership’s Sec. 754 election must be signed by a ...

The Internal Revenue Service and Treasury Department launched a new initiative Monday aimed at closing a significant tax loophole often used by the super wealthy. The IRS said ending "partnership ...

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 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 ...

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 ...

If you ever receive a K-1 from a partnership, send it to your accountant without looking at it and expect that your accountant is tracking things thoroughly, pay attention. If you do your own return, ...

A partnership is a formal agreement between two or more individuals to form a business entity, share the responsibility of liabilities, and distribute profits. The United States doesn't have a ...