IRS Announces "Pause" in Issuing New MLP Qualifying Income Rulings


The Internal Revenue Service (IRS) has temporarily stopped issuing new master limited partnership (MLP) qualifying income private letter rulings

The IRS is re-assessing what types of qualifying income private letter rulings they should be issuing. When that study is complete, they will begin entertaining ruling requests based on the new policy. However, while the study is in progress, the IRS may continue to issue rulings on issues that they think are obviously correct and will not be implicated by the new policy.

The IRS undertook a similar process in the real estate investment trust (REIT) area last year which resulted in only modest changes in its REIT ruling policy, but that does not mean that the result of the MLP study will be the same.

IRS Circular 230 Disclaimer: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.


Topics:  IRS, Master Limited Partnerships, Partnerships

Published In: Business Organization Updates, General Business Updates, Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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