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17 April 2025

Treasury Department announces intent to withdraw regulations that identified partnership related party basis-shifting transactions as transactions of interest

The IRS and Treasury Department in Notice 2025-23, on April 17, 2025, announced their intent to withdraw Treas. Reg. Section 1.6011-18, which identifies certain partnership related party basis-shifting transactions as transactions of interest (see Tax Alert 2025-0360). Notice 2025-23 also provides immediate relief from corresponding penalties imposed by IRC Sections 6707A(a), 6707 and 6708 related to such transaction of interest reporting for participants and material advisors. Notice 2025-23 also withdraws an earlier notice (Notice 2024-54), which outlined certain proposed regulations intended to be issued as to the tax treatment of partnership related party basis-shifting transactions. A Tax Alert is forthcoming.

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

Document ID: 2025-0920

 

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