KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions
Initial analysis and observations
Initial analysis and observations
The U.S. Department of the Treasury and IRS on June 17, 2024, released three guidance packages related to certain “basis-shifting” transactions involving partnerships and related parties (and certain tax-indifferent parties) that the government perceives as abusive.
- Notice 2024-54 announces the Treasury and the IRS’s intent to publish two sets of forthcoming proposed regulations related to certain partnership related-party basis adjustment transactions (covered transactions).
- In addition, Treasury and the IRS released proposed regulations identifying those covered transactions and substantially similar transactions as transactions of interest (TOI).
- Finally, Treasury and the IRS released Rev. Rul. 2024-14 clarifying when the economic substance doctrine (ESD) may apply to disallow tax benefits associated with covered transactions.
Read a June 2024 report prepared by KPMG LLP that provides initial analysis and observations on the notice, proposed regulations, and revenue ruling.
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