In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally ...

For stock to qualify for the exclusion of taxable gain under Internal Revenue Code Section 1202, the issuing corporation must satisfy the Gross Assets Test, which generally requires that the ...

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 ...

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 ...

WASHINGTON, DC - JANUARY 31: U.S. President Donald Trump talks to reporters after signing an executive order, "Unleashing prosperity through deregulation," in the Oval Office on January 31, 2025 in ...

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.