Name
Partnership Taxation: Subchapter K Update: What Came, What Went, What Survived
Speakers
Date & Time
Wednesday, January 13, 2027, 9:00 AM - 10:15 AM
Description
A survey of the year's subchapter K guidance and planning developments, headlined by the unwinding of the 2024 basis-shifting regulations: Notice 2025-23 and the 2026 proposed removal of the Treas. Reg. section 1.6011-18 transaction-of-interest rules eliminated the reporting obligations, but Revenue Ruling 2024-14's economic-substance theory survives, leaving the IRS a live challenge even without the disclosure framework. The panel also takes stock of OBBBA's permanent passthrough provisions beyond QBI—the excess-business-loss limitation and the survival of carried interest—and the structuring questions practitioners are working through as the guidance landscape resets.