The IRS said it will propose new regulations and release a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships.
The agency said it will also bring in outside experts to help root out the use of what it described as "abusive partnership transactions" and set up new teams so it can focus on the issues.
"In essence, basis shifting amounts to a shell game, where sophisticated tax maneuvers take place by shifting the basis of assets between closely related entities, ultimately allowing the high-income [taxpayers] to hide from a tax bill," IRS Commissioner Danny Werfel said.
"These complicated maneuvers take time and resources for the IRS to uncover,” he said. “They're not easy to spot on the surface of the tax return. The new guidance is aimed at telling the tax community that the IRS considers these transactions inappropriate."