Marketing to Millennials
CorpCast Episode 7: Better Know a Judge: the Honorable Mary M. Johnston of the Delaware Superior Court
Top Three Cybersecurity Misconceptions
Preparing a Company to Deal With Activist Investors
How can someone prepare for the first meeting with an attorney?
CorpCast Episode 6: A Brief Introduction to the Delaware Rapid Arbitration Act
The Intersection of Cyber and D&O Coverage
Talking PTAB with Bob Steinberg
Is Private/Non-Profit D&O Coverage Under Priced?
CorpCast Episode 5: The eDiscovery Big Picture
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Richard Bistrong Weighs in on the FIFA Scandal and Takedowns
Meritas Capability Webinar - Avoiding Common Mistakes Companies Make When Operating a Business Aircraft
FCPA Compliance and Ethics Report-Episode 161-Gini Dietrich on how to create a MasterClass
What is the Current State of Anti-Bribery Compliance & Enforcement in Australia?
Halliburton: Good for the Plaintiffs’ Bar?
Debt Financing Trends – Joe Price, Member, Corporate & Securities Practice
Venture Capital Trends: East Meets West – Lewis Geffen, Co-chair, Venture Capital Practice
Can an employer require drug testing in the workplace?
Paths to Dispute Resolution
The IRS has advised that the flip partnership guidelines under Rev. Proc. 2007-65, 2007-2 C.B. 967, do not apply to solar facilities or other projects claiming the Section 48 investment tax credit (ITC). The statement, made...more
The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...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
The IRS proposed regulations [REG-132634-14] to provide guidance on what is “qualified income” from a publicly traded partnership’s (PTP) activities regarding minerals or natural resources, such as oil and gas fracturing...more
On May 5, 2015, the Internal Revenue Service (“IRS”) released proposed regulations that, if finalized, would provide guidance on qualifying income from minerals and natural resources activities for master limited partnerships...more
On May 6, 2015, the Internal Revenue Service (IRS) published proposed regulations [REG-132634-14], which if finalized would clarify that income from certain oil and natural gas fracturing (“fracking”) services is “qualifying...more
On Wednesday (May 6th, 2015), the Treasury Department published proposed regulations under Section 7704(d)(1)(E) of the Internal Revenue Code that define qualifying activities of publicly-traded partnerships with respect to...more
The Internal Revenue Service (IRS) recently issued proposed regulations addressing master limited partnership (MLP) qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code. This Locke Lord QuickStudy...more
On May 5, 2015, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations that provide much-anticipated guidance on the scope of qualifying income under Section 7704(d)(1)(E) of the...more
On Tuesday, May 5, 2015, the Internal Revenue Service (“IRS”) released proposed regulations defining qualifying income for Master Limited Partnerships (“MLPs”). MLPs are publicly traded partnerships that are taxed as a...more
Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources.
On May 5, 2015, the Internal Revenue...more
Today, the IRS released anxiously awaited proposed regulations defining qualifying income for publicly traded partnerships, usually referred to as “master limited partnerships” (MLPs). ...more
On May 5, 2015, the IRS issued proposed regulations that provide guidance on whether income from activities with respect to minerals or natural resources is qualifying income for publicly traded partnerships (MLPs). The...more
Since the first wind deal utilizing a partnership in 2003 (also known as a “partnership flip,” a “pre-tax after-tax partnership,” or a “wind safe harbor partnership structure”), there has been a constant evolution of...more
Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more
Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more
How do tax issues change for energy companies in a distressed environment?
KS: Companies in a distressed environment often generate substantial losses which may need to be funded with additional debt or equity...more
Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more
..In January, the PA Department of Revenue advised the tax community that it had - in November - joined the Multistate Tax Commission's corporate tax audit program, in order to increase the effectiveness and efficiency of PA...more
The IRS announced that it has made significant progress on its publicly traded partnership (“PTP”) guidance and is lifting its moratorium on private letter rulings that started in 2014. ...more
In This Issue:
- U.S. International Tax Policy: 10 Questions for 2015
- The New UK Diverted Profits Tax
- France Implements Horizontal Tax Consolidation
- China’s New General Anti-Avoidance Rules: An...more
Pennsylvania’s employers need to pay close attention to the developing fiscal crisis confronting Pennsylvania policy makers in the months ahead. None of Pennsylvania’s major industries should conclude that they are protected...more
In the recently decided case PPL Electric Utilities Corp. v. Director, Drinker Biddle was successful in convincing the New Jersey Tax Court that neither the Pennsylvania capital stock tax nor the gross receipts tax are...more
In selecting a form of business entity for an oil patch deal in Texas the organizer or initial owners can consider the following five business entity forms:
Following Historic Boardwalk Hall LLC v. Commissioner, 694 F.3d 425 (3d Cir. 2012), which rejected a partnership's allocation of rehabilitation tax credits to a purported partner, the Internal Revenue Service (IRS) recently...more
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