News & Analysis as of

Oil & Gas Internal Revenue Code (IRC)

Polsinelli

Hydrocarbon Tax Policy Trends

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As governments focus on clean energy and carbon reduction initiatives, their oil and gas taxation policies have increasingly come under scrutiny. Polsinelli’s attorneys review a few overarching themes concerning expected...more

Morgan Lewis

Successful Oil Excise Tax Challenge Leads to Opportunities and Uncertainty for Exporters

Morgan Lewis on

A recent challenge to the constitutionality of the federal excise tax on domestic crude oil exported from the United States proved successful in the US Court of Appeals for the Fifth Circuit. While the US Department of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Passes Landmark Bill With Climate, Tax, Energy and Health Care Implications

On August 7, 2022, the Senate passed the Inflation Reduction Act (the Act), which is expected to have a significant impact on climate, tax and health care policy in the United States. The result of intense negotiations among...more

McDermott Will & Emery

Weekly IRS Roundup June 27 – July 1, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 27, 2022 – July 1, 2022...more

McDermott Will & Emery

Weekly IRS Roundup April 24 – April 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2022 – April 30, 2022... April 25, 2022: The IRS issued a news release, soliciting...more

Eversheds Sutherland (US) LLP

Green Tax - Volume 1

Welcome to Green Tax, Vol. 1. Each quarter we will provide a recap of some of the important energy tax issues of the last quarter, including court rulings, IRS rulings and guidance, legislative activity, and more....more

Holland & Knight LLP

Offshore Lenders Targeted by IRS Audit Campaign

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Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more

Mayer Brown

Final Like-Kind Exchange Regulations Contain Much-Needed Clarity for Natural Resource-Related Assets

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In December of 2020, the US Internal Revenue Service (the “IRS”) issued final regulations (T.D. 9935) (the “Final Regulations”) on like-kind exchanges under Section 1031 of the Internal Revenue Code of 1986, as amended. The...more

Bracewell LLP

2020 Post-Election Analysis: Issue by Issue

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FIRST 100 DAYS - As President-elect Biden stands poised to assume the office he has aspired to for the past three decades, he inherits a national crisis not unlike the one he stepped into as vice president nearly 12 years...more

Bracewell LLP

Treasury Releases Long-Awaited Proposed Regulations under Section 45Q

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On May 28, 2020, the Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which provides a credit for the capture...more

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

Foley & Lardner LLP on

On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

King & Spalding

IRS Rules that Oil and Gas Infrastructure Assets Yield Good REIT Income

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On February 15, 2019, the Internal Revenue Service (the “IRS”) released PLR 201907001 (the “Ruling”), a private letter ruling addressing whether certain income related to the leasing of an oil and gas platform, selling of...more

Opportune LLP

Proposed Bonus Depreciation Regulations Favorable For Certain Energy Partnership Transactions

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President Trump signed into law the Tax Cuts and Jobs Act (the “TCJA”) on December 22, 2017. Included in the TCJA were amendments to IRC §168(k), which permits taxpayers to expense 100% of the costs of certain qualified...more

Burr & Forman

South Carolina Legislative Tax Update: Governor Signs Bill Amending South Carolina Tax Law to Conform With the Internal Revenue...

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Differences in federal and state tax laws can cause taxpayer headaches, and often lead to incorrect state tax filings. While South Carolina’s tax code continues to treat certain items differently than the Internal Revenue...more

Robinson & Cole LLP

Green Tax Incentive Compendium - January 2016

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GENERAL DESCRIPTION. The Federal Internal Revenue Code provides a business income tax credit in the amount of $0.023 (2015) per kilowatt hour of electricity produced from qualifying renewable resources during a ten-year...more

Dechert LLP

Publicly Traded Partnership Proposed Regulations

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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

Bergeson & Campbell, P.C.

Additional Language Introduced To Be Attached To The Alternative Fuel Tax Credit

On March 26, 2015, Representative Todd Young (R-IN) introduced H.R. 1665, the Alternative Fuel Tax Parity Act, to amend the Internal Revenue Code of 1986 to equalize the excise tax on liquefied natural gas (LNG) and liquefied...more

Dechert LLP

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

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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

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