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Master Limited Partnerships Internal Revenue Code (IRC)

Vinson & Elkins LLP

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax

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On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum...more

Locke Lord LLP

The Proposed Tax Cuts and Jobs Act and MLPs

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On November 2, the House Ways and Means Committee released the Tax Cuts and Jobs Act (the “Act”). The Act is over 400 pages and was accompanied by a section-by-section summary that itself reached 82 pages. The Act is aimed at...more

Orrick, Herrington & Sutcliffe LLP

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

Locke Lord LLP

IRS Releases Final Treasury Regulations on MLP Qualifying Income

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On January 24, 2017, the Internal Revenue Service (IRS) issued final regulations addressing master limited partnership (MLP) qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code (the Code). The...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

McGuireWoods LLP

Tax Policy Update

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NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

Dechert LLP

Publicly Traded Partnership Proposed Regulations

Dechert LLP on

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

Porter Hedges LLP

News Alert: "Treasury Department Issues MLP Proposed Regulations on Qualifying Income"

Porter Hedges LLP on

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

Locke Lord LLP

Locke Lord QuickStudy: Proposed Regulations Issued on MLP Qualifying Income

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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

Latham & Watkins LLP

IRS Proposes Guidance for Determining MLP Qualifying Income

Latham & Watkins LLP on

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

Locke Lord LLP

Locke Lord QuickStudy: The Fate of Partnerships Under President Obama’s 2016 Proposed Budget

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On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more

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