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UK budget 2015

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

Ship on course but choppy waters abound! UK Budget 2015: 10 key measures impacting business

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

Distressed Energy Sector Creates Need for Thoughtful Tax Planning

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

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

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

PA Short Notes - March 2015

..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

IRS Resumes Publicly Traded Partnership PLRs – New Formal Guidance Expected

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

Focus on Tax Strategies & Developments - March 2015

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

Budget Negotiations and Business Tax Issues Likely to Impact Pennsylvania Employers Amid Fiscal Crisis

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

Recent New Jersey Tax Court Decision Creates Income Tax Refund Opportunity

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

Life Cycle Of A Company – Choice Of Entity And Key Contents Of Organization Documents

I. GENERAL. A. Introduction. 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: • Corporation •...more

IRS Publishes Safe Harbor for Monetizing Certain Tax Credits

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

Contemplating IRS Safe Harbor for Rehabilitation Credits and Its Impact on the Energy Investment Tax Credit

The IRS recently issued Revenue Procedure 2014-12, providing a safe harbor under which the IRS will not challenge partnership allocations of “section 47” federal rehabilitation tax credits. In the aftermath of the IRS’s win...more

Tax Measures in UK Chancellor’s 2013 Autumn Statement

Statement builds on economic stability, with a focus on certainty for business. On 5 December, UK Chancellor of the Exchequer George Osborne released the 2013 Autumn Statement with measures designed to increase...more

Mixing Oil and Vinegar - Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the Investment Return of...

Overview - Master Limited Partnerships are publicly traded partnerships. As of 2010, the market capitalization of MLPs was $220 billion. These publicly traded partnerships invest primarily in energy and associated...more

Massachusetts Rules Against Taxpayer on Treatment of Intercompany Debt—Again

In what is becoming a trend, the Massachusetts Appellate Tax Board (the "ATB") has issued yet another decision denying true debt treatment for an intercompany obligation. In National Grid Holdings, the ATB upheld assessments...more

Senate Hearing on Extending the MLP Rules to Renewables

On July 31, 2013, the Senate Finance Subcommittee Energy, Natural Resources, and Infrastructure held a hearing on the Master Limited Partnership Parity Act (S. 765). The bill would extend the master limited partnership (MLP)...more

Spotlight on Tennessee: 2013 Tax and Related Legislation

The 2013 Session, 108th General Assembly, considered numerous tax and related initiatives, many of which passed. The subject matter of these initiatives this year was very broad, ranging from efforts toward amending the...more

Financial Innovation for Clean Energy Deployment: Congress Considers Expanding Master Limited Partnerships for Clean Energy

Technological innovation is driving renewable energy towards a future where it is cost competitive without subsidies and provides a growing share of America’s energy. But for all the technical progress made by the clean...more

Washington Energy Update - April/May 2013

In This Issue: - DOE Begins to Authorize Pending LNG Export Applications — Cautiously - Senators Want to Extend Master Limited Partnerships to Renewables - FERC Takes on Formula Rate Protocols - Energy...more

Tax-Efficient Capital Vehicles for Unregulated Utilities: REITs, MLPs and Up-Cs Considered

Over the last several years, a confluence of political and market developments have made capital for renewable energy projects harder to come by, which has affected the ability of unregulated affiliates of public utilities...more

MoFo New York Tax Insights - Volume 4, Issue 5 - May 2013

In This Issue: New York Enacts Significant Changes to Related Member Royalty Add-Back Law; Nuclear Power Plant That Produces Steam and Water to Generate Electricity Not Eligible for Investment Tax Credit; Appellate...more

Master Limited Partnership Parity Act, Nuclear Waste, and the Investment Tax Credit– ML Strategies Weekly Energy and Environmental...

This week’s Energy & Environment Update recaps the very busy past week for energy and environmental issues both on and off Capitol Hill. Senator Coons introduced the Master Limited Partnership Parity Act on Wednesday. ...more

Proposition 39 – Analysis and Status of Implementation Current as of: 2/14/13

In November 2012, Proposition 39 was approved by the voters of California. Prior to Proposition 39, corporations were given two options to calculate their state tax liability under California law. Proposition 39 eliminated...more

PA Tax Law News - February 2013

In This Issue: PA Governor Proposes Corporate Tax Cuts; Add-Back Legislation Reintroduced; PA Supreme Court Issues Business/Nonbusiness Income Decision; Philadelphia Property Reassessments; Commonwealth Court Addresses...more

Congress Approves The American Taxpayer Relief Act Of 2012, Preventing "Fiscal Cliff"

After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more

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