From www.thetaxadviser.com: (US context) The IRS has issued final regulations identifying certain partnership related-party basis-shifting transactions as transactions of interest, which now face reportable transaction rules.
The regulations aim to close tax loopholes, projected to add over $50 billion to government revenue over ten years, by requiring disclosures that will help the IRS assess and enforce compliance.
Key changes from the proposed regulations include raising the dollar threshold for basis increases in a TOI from $5 million to $25 million for prior tax years and extending the disclosure deadline for affected taxpayers and advisers.