In an effort to combat the abusive use of partnerships for tax evasion, the Internal Revenue Service (IRS) has announced several new measures and guidance. The IRS is establishing a dedicated group in the Office of Chief Counsel to develop guidance on partnerships and close tax loopholes used by high-income taxpayers and corporations, particularly in the area of ‘basis-shifting’ transactions. These measures, which will be supported by increased auditing and reporting requirements, have been necessitated by the potential cost of these abusive transactions to taxpayers, estimated at over $50 billion over 10 years. The focus on partnerships forms part of the IRS’s ongoing commitment to high-income compliance issues and combating tax evasion.