S 2094 United States Senate · 119th Congress

Basis Shifting is a Rip-off Act

This bill targets tax avoidance tactics known as "basis shifting" in partnerships involving related parties. It requires partners to recognize gain when receiving property distributions from partnerships where related parties are involved, preventing them from artificially increasing the tax basis of partnership assets to reduce future taxable gains. The law defines "applicable partnerships" broadly (including any with related-party transactions) but excludes qualifying small businesses meeting gross receipts tests. Key provisions mandate that basis adjustments for distributed property must align with recognized gain, and increase penalties for understatements related to these transactions. It directly affects partnerships engaging in related-party distributions that previously allowed basis-shifting to defer or avoid taxes.
Bill status in committee 1 of 4 stages cleared
Introduction
Jun 2025
Committee Review
Floor Vote
President
Introduced Jun 17, 2025 Last action Jun 17, 2025
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Full legislative history

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2
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0
Committee
1
Jun 17, 2025
Committee
Read twice and referred to the Committee on Finance.
upper
Jun 17, 2025
Introduced
Introduced in Senate
upper
1 primary · 0 co-sponsors

Sponsors

Role
Legislator
Party
State
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P
Photo of Ron Wyden
Ron Wyden
DDemocratic
OR
n/a