The IRS and Treasury recently announced their intent to remove basis-shifting transaction-of-interest (TOI) regulations.
Notice 2025-23, published last week, provides immediate relief from penalties under Secs. 6707A(a), 6707(a) and 6708 for any failure by participants or material advisers to file disclosure statements or maintain lists required by the regulations.
The notice stated that it withdraws the proposed regulations to address partnership related-party basis-shifting transactions it announced in 2024.
The government plans to remove the Regs. Sec. 1.6011-18 basis-shifting TOI regulations issued in January that identified several types of partnership related-party basis-adjustment transactions as TOIs. Learn more.