The Internal Revenue Service building in Washington, D.C. Photo: Diego M. Radzinschi/ALM Attorneys May Be on the Hook for Advocating Transactions Deemed 'Abusive' by Pending IRS Rule
New regulations casting a closer eye on "basis shifting transactions" could be neutered by the Supreme Court's recent ruling overturning the "Chevron" doctrine.
July 11, 2024 at 05:00 AM
7 minute read
Law Firm Client Relationships
What You Need to Know
- In June, the IRS published new rules that, if implemented, would count basis shifting as a transaction of interest to the agency, compelling parties involved to comply with reporting requirements.
- The new rules are the latest in the agency's effort to crack down on transactions and tax structures it considers abusive.
Tax and deal lawyers are preparing for enhanced regulatory oversight of wealthy clients engaging in what the Internal Revenue Service considers "abusive" basis-shifting transactions, following last month's proposed rules by the tax collecting agency.
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