Consistent with its efforts to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, and large corporations, on June 17, 2024, the IRS unveiled a series of documents taking aim at basis shifting transactions by related-party partnerships. These documents are:
- IRS Fact Sheet FS 2024-21, which announces the new IRS program;
- Revenue Ruling 2024-14, identifying transactions the IRS claims lack economic substance;
- Notice 2024-54, previewing planned regulations; and
- Proposed regulations that identify certain types of basis-shifting transactions as transactions of interest, which are a form of reportable transaction (REG-124593-23).
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
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