Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
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
New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions.
On October 4, 2016, the Internal Revenue Service (IRS)...more
Tax partnerships, including MLPs, seeking to restructure debt face peril and possibility during challenging times.
With the lowest oil prices in more than a decade and the equity markets effectively closed to them, oil...more
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
10/9/2015
/ Commodities ,
Energy Sector ,
Exploration and Production Assets ,
IRS ,
Liquid Natural Gas ,
Marketing ,
Master Limited Partnerships ,
Mineral Exploration ,
Mineral Leases ,
Minerals ,
Oil & Gas ,
Passive Activity ,
Pipelines ,
Private Letter Rulings ,
Qualifying Income ,
Surface Transportation ,
U.S. Treasury ,
Underground Injection Wells
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
IRS announces end of moratorium on MLP letter ruling requests.
The IRS has resumed the ruling process for private letter ruling (PLR) requests regarding qualifying income issues for MLPs under section 7704. An official...more