News & Analysis as of

Oil & Gas Qualifying Income

Akin Gump Strauss Hauer & Feld LLP

Final Regulations on MLP Qualifying Income Provide Clarification

Final regulations issued by the Treasury and the Internal Revenue Service (IRS) on January 19, 2017, revealed a set of new rules interpreting “qualifying income” under Section 7704(d) of the Internal Revenue Code, affecting...more

Latham & Watkins LLP

IRS and Treasury Finalize Guidance Determining MLP Qualifying Income

Latham & Watkins LLP on

Regulations provide rules for determining MLP qualifying income from certain mineral or natural resource-related activities and services. On January 19, 2017, the US Department of the Treasury (Treasury) and the Internal...more

Bracewell LLP

Treasury and IRS Release Final Regulations on Qualifying Income, but Halted by Trump Moratorium

Bracewell LLP on

January 25, 2017 On January 19, 2017, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding qualifying income under Internal Revenue Code (Code) section...more

Orrick, Herrington & Sutcliffe LLP

Midnight Regulations Provide Oil & Gas MLPs with Favorable Answers; New Administration Immediately Withdraws

On January 19, 2017, less than 24 hours before the change of administration, the IRS and Treasury released much-anticipated final regulations under Code section 7704(d)(1)(E) setting parameters for qualifying income for...more

Latham & Watkins LLP

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

Latham & Watkins LLP on

IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing. “I’m mad as Hell, and, frankly, I’m not going to take it anymore.” — Paraphrase of concerned citizen and...more

Eversheds Sutherland (US) LLP

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...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

Goulston & Storrs PC

Proposed Regulations on Publicly Traded Partnerships Affect Natural Resource Industry

Goulston & Storrs PC on

The IRS proposed regulations [REG-132634-14] to provide guidance on what is “qualified income” from a publicly traded partnership’s (PTP) activities regarding minerals or natural resources, such as oil and gas fracturing...more

K&L Gates LLP

New MLP Rules Provide Bright Lines and New Challenges

K&L Gates LLP on

On May 5, 2015, the Internal Revenue Service (“IRS”) released proposed regulations that, if finalized, would provide guidance on qualifying income from minerals and natural resources activities for master limited partnerships...more

BakerHostetler

IRS Publishes Proposed Regulations Addressing Fracking Services by MLPs

BakerHostetler on

On May 6, 2015, the Internal Revenue Service (IRS) published proposed regulations [REG-132634-14], which if finalized would clarify that income from certain oil and natural gas fracturing (“fracking”) services is “qualifying...more

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