In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally ...

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 ...

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by ...

A partner’s tax basis in his partnership interest (referred to as “outside basis”) generally represents his economic investment in a partnership plus his share of the partnership’s liabilities. In ...