Associate Attorney Jeremy Simpson provides detailed analysis of the IRS’s final regulations on basis-shifting transactions of interest in Tax Notes. He examines new disclosure requirements for certain partnership transactions involving related parties—regulations aimed at curbing potential tax avoidance. Simpson outlines how the changes affect taxpayers, material advisers and private equity funds, and offers practical guidance for navigating compliance and avoiding costly penalties.
Read the full article in Tax Notes.
Jason Wiggam
Founding Partner
Jason is a founding partner of Wiggam Law in Atlanta, Georgia. His practice focuses on representing individuals, businesses, officers, directors, shareholders, and partners in matters concerning the Internal Revenue Service (IRS), the Georgia Department of Revenue, and other state tax departments. He has successfully represented clients in the IRS’s recent crackdowns on syndicated conservation easements and micro-captive insurance disputes. Jason also has significant experience handling IRS tax settlements, tax compliance, appeals representation, offshore foreign bank reporting compliance, audit representation from responding to IRS audit letters through to IRS audit reconsiderations if necessary, innocent spouse relief, IRS levy and IRS garnishment releases, penalty waivers/abatements, and lien releases/withdrawal.
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