Securities Energy & Utilities Tax

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Fibra E | Energy and Infrastructure Investment vehicle

On September 17, drafts of the Fourth Set of Amendments to the Annual Tax Regulations issued by the Ministry of Finance for the fiscal year 2015 (“Tax Regulations”)1and the amendments to the general provisions applicable to...more

Corporate & Financial Weekly Digest - Volume X, Issue 27

In this issue: - Court of Appeals for Third Circuit Overturns District Court Ruling Regarding Exclusion of Shareholder Proposal From Proxy Statement - FINRA Updates Its Interpretation of the SEC's Financial...more

Canada's Resource Revenue Transparency Rules Now in Force

Canada's new Extractive Sector Transparency Measures Act was proclaimed in force today, in keeping with the federal Government's committed timeline. The Act imposes mandatory reporting requirements for each entity engaged in...more

Proposed Regulations on Publicly Traded Partnerships Affect Natural Resource Industry

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

IRS Releases Proposed New Rules for MLP Qualifying Income

Today, the IRS released anxiously awaited proposed regulations defining qualifying income for publicly traded partnerships, usually referred to as “master limited partnerships” (MLPs). ...more

Exploration Development Incentive Passes Australian Senate

On 3 March 2015, legislation introducing the Exploration Development Incentive (EDI) officially passed the Australian Senate. The legislation is expected to receive Royal Assent in the coming days. The EDI has been introduced...more

Welcome Tax Measures Announced at the PDAC 2015 Convention

On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more

Sol-Wind’s IPO Compared to YieldCos & Structures of Other MLPs

Yesterday, Sol-Wind filed its S-1 with the Securities & Exchange Commission for its listing on the NYSE. Its ticker symbol will be SLWD. Here is a link to my structure diagrams for Sol-Wind and comparisons of it to a...more

Some Welcomed Recognition for Exploration Mining Companies

As market sentiment and investor confidence in Australia's extractive industries remains subdued, recent initiatives from governments and regulators demonstrate, at least, an acknowledgment of the issues faced by mineral...more

Layne Christensen Settles SEC FCPA Probe

-- Negligible Evidence of Business Nexus Element May Explain DOJ Declination - Consenting to a October 27, 2014, Cease and Desist Order, the global water management, construction and drilling company Layne Christensen...more

Mozambique's New Petroleum Legislation: Are Investors Ready to Hit the Gas?

Mozambique’s new Petroleum Law and new Petroleum Tax Law have been long awaited by foreign investors who have been looking for a clear and comprehensive legal framework to facilitate investment in the development of the...more

Legislative Report – MLP Parity Act

What: The MLP Parity Act (the “Act”) is a bill currently before the U.S. Senate Committee on Finance seeking to expand Section 7704(d) of the Internal Revenue Code (which defines “qualifying income” for publicly traded...more

Federal Budget, Economic Action Plan 2013

On March 21, 2013, the Minister of Finance tabled the 2013 federal budget, Economic Action Plan 2013. There are announced changes which will be of particular interest to the mining sector....more

"SEC Filing Illustrates Recent REIT Trend: Holding and Financing Renewable Energy Assets"

Sponsors and investors have been paying much attention to the potential use of real estate investment trust (REIT) structures to hold and finance renewable energy assets in a tax-efficient way. A recent SEC filing by Hannon...more

No-Action Relief Excludes Tax Blocker Entity from Definition of Investment Company

On August 30, 2012, the SEC’s Division of Investment Management said that it would not recommend enforcement action if an oil and natural gas company implementing an alternative capital structure did not register as an...more

IRS Defends Discretion to Withhold Section 1256 Exchange Designation for ISOs

The IRS defended its decision not to designate independent system operators as qualified board or exchange (QBE) principally on the grounds that, as a matter of law, it is not required to designate any exchanges as QBEs under...more

RegLINC - May 2010

INSIDE THIS ISSUE: *Proposed 2011 budget eliminates fossil fuel tax incentives - 2 *PHMSA final rule — HazMat security regulation - 2 *Oil spill prevention, control, and countermeasure - 3 *Federal Motor Carrier Safety...more

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