News & Analysis as of

Administrative Procedure Act Internal Revenue Code (IRC) Proposed Regulation

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

Fox Rothschild LLP on

The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Latham & Watkins LLP

US Tax Court Voids Penalties Affecting Syndicated Conservation Easements; Treasury Reacts With Proposed Regulations

Latham & Watkins LLP on

The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more

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