This CLE/CPE course will provide tax counsel with comprehensive guidance on the 754 election for partnerships. The panel will discuss the basis adjustment rules associated with sales, transfers, and ...

Under final regulations issued Thursday by the IRS and Treasury (T.D. 9963), partnerships electing to adjust the basis of partnership property under Sec. 754 will not have to include a partner’s ...

A partner’s “basis” in the partnership interest is the partner’s interest in the partnership for tax purposes. It is used to determine the tax imposed upon cash distributions, gain or loss on sale, ...

On June 17, 2024, the IRS released Notice 2024-54, which states that the IRS and the Treasury Department intend to issue proposed regulations relating to partnership basis adjustments resulting from ...

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 and Treasury have now finalized regulations that require partnerships to disclose information about certain transactions involving distributions and transfers of partnership interests and ...

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 ...

There’s been a spike in news about the Internal Revenue Service (IRS) cracking down on tax evaders. While some instances of tax evasion are intentional, such as abusing tax havens or undertaking ...