News & Analysis as of

U.S. Treasury Tax Basis

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Holland & Knight LLP

IRS Cracking Down on "Basis-Shifting" in Related-Party Partnership Transactions

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more

Nutter McClennen & Fish LLP

Partnership Transactions and Bonus Depreciation: A Narrow Path

The recently issued bonus depreciation regulations should influence – but not control – how we structure certain partnership contributions and distributions. These transactions include partnership mergers and divisions....more

Tucker Arensberg, P.C.

Fiduciary Alert: IRS Again Extends Time for Consistent Basis Reporting via Form 8971 until June 30, 2016

Tucker Arensberg, P.C. on

Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more

Blank Rome LLP

Anticipated IRS Regulations May Impact Discounts On Intra-Family Transfers of Closely Held Business Interests

Blank Rome LLP on

Action Item: It is anticipated that Treasury will soon issue new regulations that will affect the valuation discounts applicable to intra-family transfers of interests in closely held entities. It may be advisable to review...more

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