The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
4/17/2018
/ Bi-Partison Balanced Budget Act (BBA) ,
Corporate Taxes ,
Energy Sector ,
FCC ,
FIRPTA ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
IRS ,
Like Kind Exchanges ,
Loss-Carryover ,
Net Operating Losses ,
New Rules ,
Opt-Outs ,
Partnership Agreements ,
Partnerships ,
Push-Out Requirements ,
Tax Audits ,
Tax Cuts and Jobs Act
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/1/2018
/ Audits ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
FIRPTA ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
TEFRA ,
Underpayment
In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more
8/8/2017
/ Business Taxes ,
FIRPTA ,
Foreign Partner ,
Income Taxes ,
International Tax Issues ,
IRS ,
Non-US Entities ,
Partnership Interests ,
Partnerships ,
Tax Court ,
Tax Liability