Tax and deal lawyers are preparing for enhanced regulatory oversight of wealthy clients engaging in what the Internal Revenue Service considers “abusive” basis-shifting transactions, following last month’s proposed rules by the tax collecting agency.

Not only would the new rules enhance disclosure requirements for high net-worth clients, but the lawyers and accountants who advocate for alleged tax avoidance schemes may also find themselves under increased regulatory scrutiny. Meanwhile, many lawyers say the regulatory authority of federal agencies such as the IRS has been undermined by the U.S. Supreme Court’s recent ruling overturning the Chevron doctrine.