The IRS is announced a dedicated group in the Office of Chief Counsel focused on developing guidance on partnerships, including closing loopholes. The group will work with a pass-through group to be established this fall in the IRS Large Business and International division.
In addition, the IRS issued three pieces of guidance that it said stems from discoveries by IRS audit teams.
These guidance aims to halt the use of “basis shifting” transactions that use related-party partnerships to avoid tax. In this process, taxpayers strip basis from assets they own where the basis is not generating tax benefits and move it to assets where it will.
The Department of the Treasury estimates such transactions could cost taxpayers more than $50 billion over 10 years.
The IRS notes it is increasing the number of audits on complex partnership and is looking at current audits and will equip examiners to identify issues on other partnership returns identified for examination as part of either the Large Partnership Compliance program, partnership audit campaigns or other selection methods.