A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
7/19/2017
/ Capital Gains ,
Foreign Investment ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Income Taxes ,
Partnership Interests ,
Partnerships ,
Reversal ,
Tax Court ,
Transfer of Interest
The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more
The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more
10/26/2016
/ Capital Expenditures ,
Debt ,
Debt Financing ,
Disguised Sales ,
Final Rules ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Risk Allocation ,
Tax Structuring ,
U.S. Treasury
The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more
There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more
The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more
The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more
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
6/24/2015
/ Corporate Taxes ,
Double Taxation ,
Energy Projects ,
Energy Sector ,
Fracking ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Partnerships ,
Master Limited Partnerships ,
Mining ,
Natural Gas ,
Oil & Gas ,
Partnerships ,
Passive Activity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Qualifying Income ,
Research and Development
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
The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more