Tax Notes quoted partner Jennifer Breen from remarks she made on a panel at the New York University School of Professional Studies’ recent tax controversy forum discussing the Internal Revenue Service’s (IRS’s) latest package of guidance addressing alleged partnership basis shifting.
Jennifer moderated a panel that included IRS Chief Counsel Marjorie Rollinson. Jennifer said that the effective date of the proposed regs could catch transactions that taxpayers might have thought were already settled, to which Rollinson replied that such catches already regularly happen with audits.
Read the Tax Notes article >>
Subscription may be required