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Trends in Oil & Gas: 2023 and the Year Ahead

The past 12 months have been some of the trickiest to navigate for oil & gas companies in recent memory. Despite high energy prices and record cashflows, there is still uncertainty about what future paths to growth might look...more

Clean Energy Tax Credit Transferability Guidance Issued

On June 14, 2023, the Internal Revenue Service and the Treasury Department issued (among other guidance) an expansive set of proposed regulations explaining how taxpayers can monetize 11 green energy tax credits through...more

Treasury Updates Guidance Issued Last Week on 'Energy Community' Tax Credit Adders

Summary - On April 4, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released guidance on the “energy community” tax credit adders (EC Adders) that were added under the Inflation Reduction Act...more

Energy Companies Contemplating Repurchase of Discounted Debt Should Carefully Analyze Corporate, Securities Law and Tax...

As the economic turbulence associated with the downturn in commodity prices and the outbreak of COVID-19 continues, many energy companies may find their debt trading at significant discounts. For companies trying to manage...more

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

New Partnership Liability and Disguised Sale Regulations

Key Points - - Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more

IRS Comes Out With Proposed Regulations Clarifying the Scope of Assets and Activities That Qualify for MLP Treatment

On May 5, 2015, the IRS issued proposed regulations that provide guidance on whether income from activities with respect to minerals or natural resources is qualifying income for publicly traded partnerships (MLPs). The...more

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