2024年10月14日
What’s the Basis for the New Partnership Basis-Shifting Rules?
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In this article, the authors argue that because the regulations proposed in Notice 2024-54 and Rev. Rul. 2024-14 are substantively flawed, it is highly uncertain whether a court would uphold their validity or would see the revenue ruling as a helpful tool in addressing IRS challenges made before the regulations are issued.
