Internal Revenue Service sign at the IRS Building in Washington, D.C. IRS Targets Related-Party Basis Shifting
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 transactions between related parties. The proposed regulations would introduce massive additional complexity to an area of the tax law that is already complicated.
August 27, 2024 at 10:30 AM
6 minute read
In many simple cases, a partner's tax basis in his partnership interest (so-called "outside basis") will equal his pro rata share of the partnership's tax basis in its assets (so-called "inside basis"). However, there are various transactions that may cause a disparity between inside basis and outside basis to occur.
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