And in that case the outside basis would be high and the inside basis would be low due to the fact the assets appreciated. That's the purpose of the 754 election. But inside/outside basis can diverge.

In many simple cases, a partner's tax basis in his partnership interest (so-called "outside basis") will equal his pro rata share of the partnership's tax basis in its assets (so-called "inside ...

The new guidance aims to stop the use of basis-shifting transactions that use related-party partnerships to avoid taxes. In these complex maneuvers, high-income taxpayers and corporations strip basis ...

Create inside/outside basis disparities through various methods, ... The IRS has been adding more tax experts from outside the agency to help spot tax avoidance strategies.

For tax year 2018, any partnerships where GAAP, 704(b) or Other is checked in Item L of the Schedule K-1, or any partnership return where tax capital basis is checked (but the tax capital basis was ...

Inside, outside, or exempt? Tax implications of the movement of goods in UAE free zones. Understanding VAT in UAE designated free zones is critical for compliance. Last updated: May 21, 2025 | 06:14.

On Jan. 14, 2025, the Treasury Department issued final regulations designating certain related-party partnership basis shifting transactions as “transactions of interest.” Although this ...

I previously posted a Tax Geek Tuesday titled “Understanding Partnership Distributions, Part I.” We spent well over 3,000 words looking at the general rules governing the treatment of ...

The aggregate money and contributions made by the partners make up the inside basis of the partnership itself. Outside basis has two components: the partner's tax capital account and the partner's ...