The IRS has been putting more focus on partnerships in recent times. Back in June 2024, the IRS released a statement were the Agency would put more focus on "high-income compliance issues" and "... to combat abusive partnership transactions" which mainly related to basis shifting transactions. Then, the IRS targeted specifically three groups: " Transfer
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.
Earlier this month, the IRS has announced the new targets for their examination efforts. This information is in line with the previous discussion to target wealthy individuals over the $400,000 income threshold that was mentioned by President Joe Biden in the 2022 State of the Union speech, Treasury Secretary Janet Yellen who instructed the IRS
