July 10, 2024

IRS Partnership Crackdown Move Likely Moot Due to Supreme Court

Bloomberg Law
Lee S. Meyercord | Mary A. McNulty

Tax attorneys Lee Meyercord and Mary McNulty co-authored an article for Bloomberg Law, discussing the challenges facing the IRS and U.S. Department of the Treasury when regulating related-party basis-shifting transactions aimed at reducing tax liabilities. They highlight impending regulations that could alter federal tax code requirements for partnership transactions amid intensified enforcement targeting partnerships and affluent taxpayers. With the U.S. Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo limiting deference to agency interpretations, these regulations, if finalized, face significant legal challenges, indicating a complex future for tax strategy and litigation in this area.

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