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Tax Shelters Administrative Procedure Act

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

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

Polsinelli on

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

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