The US Internal Revenue Department (IRS) has announced a series of measures against 'abusive' basis-shifting transactions by related-party partnerships. It has also released new guidance to stop large partnerships using sophisticated tax-free transactions that lack economic substance.
Basis-shifting schemes transfer assets from one entity to another affiliated entity, typically a pass-through entity not subject to corporate taxation, thereby lowering effective tax rates and securing extra tax deductions. The IRS says tax filings for large pass-through entities have trebled to 300,000 in the ten years to 2019.
Link：【US IRS 2024/6/17】