The Treasury Department and the Internal Revenue Service have issued notices warning about two kinds of transactions that could arouse their interest: "toggling" grantor trusts and contributions of a successor member interest in a limited liability company.

Both the Treasury Department and the IRS believe both types of transactions have the potential for abuse, but they have not gone so far as to identify them as tax avoidance transactions. The "transactions of interest" rubric is meant to be a kind of middle ground, but the transactions are nevertheless subject to disclosure.

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