On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more
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
2/6/2019
/ Corporate Taxes ,
Income Taxes ,
IRS ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Private Letter Rulings ,
Push-Out Requirements ,
Tax Audits ,
Tax-Free Spin-Offs ,
U.S. Treasury ,
Venture Capital
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
11/7/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Energy Projects ,
Investment Tax Credits ,
Investors ,
IRS ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
U.S. Treasury
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
10/18/2018
/ Business Taxes ,
Construction Industry ,
Energy Projects ,
Interim Rule ,
Investment Tax Credits ,
Investors ,
IRS ,
NAICS ,
Partnerships ,
Physical Work Test ,
Proposed Regulation ,
Protecting Americans from Tax Hikes (PATH) Act ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Reform ,
UBTI
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
9/20/2018
/ Anti-Avoidance ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Publicly-Traded Companies ,
REIT ,
SALT ,
Section 199 ,
Tax Cuts and Jobs Act ,
W-2
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
9/4/2018
/ Acquisitions ,
Arms Length Transactions ,
Bonus Depreciation ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
MACRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more
5/16/2018
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
S-Corporation ,
Special Education ,
TEFRA ,
U.S. Treasury ,
Underpayment
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
5/3/2018
/ Audits ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Private Equity Funds ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
TEFRA
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
4/6/2018
/ Base Erosion Tax ,
C-Corporation ,
Corporate Taxes ,
Entertainment Industry ,
Foreign Affiliates ,
GILTI tax ,
Income Taxes ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
Renewable Energy ,
Tax Audits ,
Tax Deductions ,
Tax Liability
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
The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more
2/16/2018
/ Base Erosion Tax ,
Corporate Taxes ,
Energy Sector ,
Holding Periods ,
International Tax Issues ,
IRS ,
Partnerships ,
REIT ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
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
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
1/26/2017
/ Final Rules ,
IRS ,
Minerals ,
Moratorium ,
Natural Gas ,
Natural Resources ,
Oil & Gas ,
Partnerships ,
Pass-Through Entities ,
Qualifying Income ,
Regulatory Freeze ,
U.S. Treasury
On October 5, 2016, the Treasury Department and Internal Revenue Service (“IRS”) published much-anticipated final, temporary and new proposed regulations providing guidance under Internal Revenue Code sections 707 and 752 on...more
On November 2, 2015, President Obama signed into law the Bipartisan Budget Agreement of 2015 (the “Act”), which includes major changes to the partnership tax audit rules (the “New Audit Rules”). The Act repeals the current...more
On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more
7/30/2015
/ Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Managers ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Safe Harbors ,
Section 409A ,
Section 457A ,
Significant Entrepreneurial Risk (SER) ,
U.S. Treasury