Episode Title: IRS Tackles Partnership Basis Shifting

Episode Description:

New rules! IRS targets partnership basis shifting as "Transactions of Interest." Higher reporting thresholds, limited retroactivity. Quick update.

Show Notes:

• IRS targets "basis shifting" as TOIs.
• Higher thresholds: $25M before '25, $10M after.
• Limited lookback: 6 years.
• Extended deadlines, PTP exceptions.
• Review your partnerships!

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