The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more
10/26/2016
/ Capital Expenditures ,
Debt ,
Debt Financing ,
Disguised Sales ,
Final Rules ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Risk Allocation ,
Tax Structuring ,
U.S. Treasury
The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more
Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more
6/24/2015
/ Corporate Taxes ,
Double Taxation ,
Energy Projects ,
Energy Sector ,
Fracking ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Partnerships ,
Master Limited Partnerships ,
Mining ,
Natural Gas ,
Oil & Gas ,
Partnerships ,
Passive Activity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Qualifying Income ,
Research and Development