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 ...
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 ...
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.
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