A German holding company and a partnership both have zero basis in a $610 million promissory note contributed to one of the ...

A partnership whose sole asset is all the stock of a corporation offers opportunities but with potential pitfalls.

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 Biden administration said large partnerships were illegally avoiding hundreds of billions in taxes. Trump says they shouldn’t have to report the transactions.

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 ...

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 ...

Yes. The deduction of a limited partner’s share of partnership losses is limited by the partnership basis, the at risk rules and the passive loss rules. Partnership basis. A partner may not deduct the ...

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 ...

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 ...