DemocratBill · S. 2094· Senate(119-S-2094)

Basis Shifting is a Rip-off Act

Rep. Wyden
Age: 77 years
Oregon
Introduced
6/17/2025
Last activity
6/17/2025 — Read twice and referred to the Committee on Finance.
Sponsored by
Ron Wyden
Cosponsors
None
Taxation
  1. Introduced
  2. In Committee

What this bill would do

This bill, titled the "Basis Shifting is a Rip-off Act," aims to modify the Internal Revenue Code regarding how partnerships handle certain transactions. It focuses on changing the rules for taxation when property or partnership interests are distributed or transferred among related parties. The legislation introduces new requirements for recognizing gain in specific "applicable partnership" scenarios. It also establishes new rules for the basis of partnership property following these distributions or transfers. Finally, the bill increases penalties for certain understatements related to these transactions.

Yes· 3 of 5

  • Does this cut taxes for small businesses?+2

    The bill includes a gross receipts test that exempts smaller partnerships from the new rules.

  • Does this make it easier to run a small business?+2

    A small business exception is provided based on gross receipts to shield smaller entities from these new rules.

  • Does this reduce what the federal government owes?+1

    By closing tax loopholes related to basis shifting, the bill may increase federal revenue.

The opposite· 3 of 8

  • Would people with substantial wealth be better off under this?-5

    The bill directly targets transactions often used by high-net-worth individuals to shift basis without tax consequences.

  • Would the very wealthiest people be better off under this?-5

    The bill creates new taxes and higher penalties for the types of complex transfers often used by this group.

  • Would billionaires be better off under this?-5

    The increased tax recognition and penalties negatively impact the tax strategies available to the ultra-wealthy.