Partnership Basis Shifting: Evaluating New Guidance Under Notice 2024-54, Revenue Ruling 2024-14, and the Proposed Disclosure Regulations

Why You Should Attend

In June of 2024, the IRS and Treasury issued guidance on basis shifting transactions among related parties aimed at putting an end to certain transactions that could be seen as generating inappropriate tax benefits.

For tax practitioners seeking a deeper understanding of Notice 2024-54, Revenue Ruling 2024-14, and the proposed disclosure regulations, PLI is delighted to present this new half-day program in which leading experts, including representatives from the IRS and Treasury, will review this guidance and discuss the implications for basis shifting partnership transactions moving forward.

What You Will Learn

After completing this program, participants will be able to:

• Identify the types of basis shifting transactions targeted by the new guidance
• Recognize partnership basis shifting transactions that will be considered reportable Transactions of Interest (“TOI”)
• Identify situations where the IRS will assert the economic substance doctrine to deny tax benefits from a basis shifting transaction
• Understand the IRS and Treasury’s rationale for focusing on related party basis shifting transactions

Who Should Attend

This program is designed for corporate tax managers, tax attorneys, accountants and anyone interested in exploring the impact of Notice 2024-54, Revenue Ruling 2024-14, and the proposed disclosure regulations on related-party basis shifting transactions.

Program Level: Overview

Intended Audience: Attorneys at law and accounting firms, in-house tax counsel and other tax professionals seeking to understand the recent IRS and Treasury guidance related to related-party basis shifting transactions.

Prerequisites: Interest in exploring the impact of Notice 2024-54, Revenue Ruling 2024-14, and the proposed disclosure regulations on related-party basis shifting transactions.

Advanced Preparation: None