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.
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