10 January 2025

Final rules issued to treat partnership related-party basis shifting transactions as transactions of interest

The IRS and Treasury Department on January 10, 2025, issued final regulations under IRC Section 6011 to treat certain partnership related-party basis shifting transactions and substantially similar transactions as transactions of interest that must be reported to the IRS by taxpayers and material advisors. The final regulations adopt the proposed regulations from June 2024 (see Tax Alert 2024-1273) with some modifications. A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2025-0194