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 partnership distribution rules create disparities between inside and outside basis in two common situations: (1) when the distributee partner recognizes gain or loss[8] on a distribution and (2) ...

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, ...

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 ...

Partnerships (which, for the purpose of this article, include limited liability companies treated as partnerships for tax purposes) have long been considered a flexible way of structuring investment ...