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On June 17, 2024, the IRS published Revenue Ruling 2024-14 as part of a package it says will raise an additional $50 billion dollars of income taxes over the next decade from “basis-shifting transactions.” In addition to the Revenue Ruling, the package includes three proposed regulations affecting basis adjustments. The Revenue Ruling seeks to curtail basis-shifting transactions between related entities by applying the economic substance doctrine to situations where the non-tax justifications for transactions are insubstantial when compared to the tax benefits associated with the transactions.

Read the full post on the Gulf Coast Business Law Blog here.

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