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Notice 2025-23

SECTION 5. WITHDRAWAL OF THE

Internal Revenue Bulletin 2025-19 · 2026-10-03 edition · updated 2026-10-04 · United States

BASIS SHIFTING NOTICE

The Basis Shifting Notice announced the Treasury Department and the IRS’s intention to publish certain proposed regulations addressing partnership related-party basis shifting transactions. Stakeholders have stated that the intended proposed regulations, if finalized, would impose complex, burdensome, and retroactive technical rules on many ordinary-course and tax-compliant business activities, creating costly compliance obligations and uncertainty for businesses. After the review directed by Executive Order 14219, the Basis Shifting Notice is hereby withdrawn.

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▸Contents — Internal Revenue Bulletin 2025-19

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