In the Fact Sheet 2024-21 Basis shifting, the IRS detailed the guidance to avoid abusive basis shifting by related-party partnership members, such as transfers, distributions or liquidations. This is part of a broader targeted effort against partnerships and high income taxpayers. For the basis shifting, the IRS described the abuse as a evasion of taxes
As the IRS is increasing the attention on partnership returns, especially those with higher asset value or more complexity, we should keep into consideration the first results of the partnerships audits subject to Bipartisan Budget Act that are now ending. The Bipartisan Budget Act (BBA) was passed in 2015, but it was effective from 2018.
As announced in July 2023 and shared in the IRS Tax Tip 2023-98, the IRS will stop the unannounced visits. Note that there has been numerous cases of fraud with people impersonating IRS agent by mail, by phone and in person requesting outstanding tax liabilities or requesting payments to avoid liens or criminal charges. The
