Notice 2025-23, page 1428.

Notice 2025-23 informs taxpayers and material advisors that final regulations regarding the identification of certain partnership related-party basis adjustment transactions as transactions of interest will be withdrawn through the forthcoming publication of proposed and final regulations and that they can rely on the notice for relief from applicable penalties for failure to file disclosure statements. In addition, Notice 2025-23 revokes Notice 2024-54, which informed taxpayers of intended proposed regulations that would provide substantive technical rules to discourage basis shifting among related partners.