The IRS Throws Down the Gauntlet to Certain Large Partnership Basis-Shifting Transactions by ROBERT S. HORWITZ and MICHEL R. STEIN
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, June 26, 2024
Consistent with its efforts to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, and large corporations, on June 17, 2024, the IRS unveiled a series of documents taking aim at basis shifting transactions by related-party partnerships. These documents are:
- IRS Fact Sheet FS 2024-21, which announces the new IRS program;
- Revenue Ruling 2024-14, identifying transactions the IRS claims lack economic substance;
- Notice 2024-54, previewing planned regulations; and
- Proposed regulations that identify certain types of basis-shifting transactions as transactions of interest, which are a form of reportable transaction (REG-124593-23).
