Latest Publications

Share:

EPA’s Final Rule for Reducing Methane Emissions in the Oil and Gas Industry

On December 2, 2023, the U.S. Environmental Protection Agency (EPA) announced a Final Rule under the Clean Air Act that will sharply reduce methane emissions from the oil and gas sector. The rule applies to sources involved...more

IRS Indefinitely Extends Use of Electronic Signatures for Section 83(b) Elections

On October 17, 2023, the U.S. Internal Revenue Service (IRS) updated its Internal Revenue Manual (IRM) to fully incorporate into the IRM certain e-signature policies and procedures permitting the use of electronic signatures...more

Inflation Reduction Act: New Guidance on Tax Credit Transfers

On June 14, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released highly anticipated guidance relating to new Internal Revenue Code (“Code”) Section 6418, which was added as part of...more

Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure

On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...more

Prevailing Wage and Apprentice Requirements for Clean Energy Tax Credits are Coming into Effect on January 29, 2023

On August 16, 2022, President Biden signed the Inflation Reduction Act (the “IRA”), which included provisions for clean energy tax and climate tax incentive credits for taxpayers – generally builders, developers and owners of...more

Inflation Reduction Act: Key Green and Blue Hydrogen and CCUS Provisions

The U.S. Congress has passed, as of today, the Inflation Reduction Act (IRA or the “Act”), which is expected to be signed into law by President Joe Biden very soon....more

The Book Minimum Tax, Pillar 2 and Creditable Foreign Income Taxes

As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more

Inflation Reduction Act of 2022: New Corporate Book Minimum Tax and Changes for Carried Interests

On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more

UK Introduces Energy Profits Levy on 'Extraordinary Profits' of Oil and Gas Companies

The U.K. Government announced on May 26, 2022 its intention to introduce with immediate effect a temporary Energy Profits Levy (the “Levy”), an additional U.K. Corporation Tax charge at a rate of 25% on the profits of oil and...more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

IRS Proposes Carried Interest Rules Recharacterizing Certain Capital Gain in Connection with Profits Interests

On July 31, 2020, the Internal Revenue Service (IRS) published proposed regulations providing guidance under Section 1061 (the “Proposed Regulations”) of the Internal Revenue Code (the “Code”). Section 1061, which was added...more

Long-Awaited Final and New Proposed Regulations Issued Under Section 163(j)

On July 28, 2020, the Internal Revenue Service and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”). These regulations...more

IRS Issues Proposed Regulations On Section 45Q Carbon Oxide Sequestration Credits

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) have issued proposed regulations (REG-112339-19) providing valuable guidance on credits for the sequestration of qualified carbon oxide...more

IRS Issues Proposed Regulations For Excise Tax On Nonprofit Executive Compensation

On June 5, 2020, the U.S. Internal Revenue Service (the IRS) issued proposed regulations on Section 4960 of the Internal Revenue Code of 1986, as amended (the “Proposed Regulations”). The Proposed Regulations are “intended to...more

Proposed Regulations Clarify UBTI ‘Silo’ Rules, Preserve Relief For Tax-Exempt Investments in Private Equity Funds

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) issued proposed regulations (REG-106864-18) addressing the so-called “silo” rule under Section 512(a)(6) of the Internal Revenue Code,...more

WTI Goes Below $0—A New World or a Bad Day?

The spot price of WTI crude oil dropped below $0 for the first time in history today. While a supply glut for crude oil exists, the true value of crude going forward is not near or below $0....more

4/22/2020  /  Crude Oil , Energy Sector , Oil Prices , OPEC

IRS Guidance Clarifies CARES Act Relief Procedures for Partnerships

The CARES Act, enacted on March 27, 2020, provides important relief for partnerships including a correction to the bonus depreciation rules for qualified improvement property (QIP) under Section 168(e) and relief relating to...more

International Considerations – Buying Assets from Distressed U.S. Companies

The oil price plunge starting on March 6 seems like a sucker-punch to the oil and gas industry after the price decreases and market unrest as a result of COVID-19. However, for those with capital to spend, including...more

Five Things to Think About – Buying Assets from Distressed Companies

The oil plunge starting on March 6 seems like a sucker-punch to the oil and gas industry after the price decreases and market unrest as a result of COVID-19. However, for those with capital to spend, it will lead to...more

Five Things to Think About – Navigating Counterparty Insolvency

The oil price plunge starting on March 6 seems like a sucker-punch to the oil and gas industry after the price decreases and market unrest as a result of COVID-19. Midstream companies that rely on long-term producer contracts...more

Five Things to Think About – Analyzing Liquidity and Planning for Challenges

The oil price plunge starting on March 6 seems like a sucker-punch to the oil and gas industry after the price decreases and market unrest as a result of COVID-19. Oil and gas companies and companies that contract with them...more

First No Contract by Ambush. Now No Contract by Email, Texas Supreme Court Says.

On February 28, 2020, the Texas Supreme Court reversed a ruling from the First Court of Appeals in Houston in the case of Chalker Energy Partners III, LLC, et al. v. Le Norman Operating LLC, 547 S.W.3d 27 (Tex. App.—Houston,...more

Texas Supreme Court Reaffirms Freedom of Contract and Rejects ‘Partnership by Ambush’

On January 31, 2020, the Texas Supreme Court (the “Court”) affirmed a ruling from the Fifth Court of Appeals in Dallas in the case of Energy Transfer Partners LP et al. v. Enterprise Products Partners LP et al, No. 529 S.W.3d...more

Treasury and IRS Issue Final Regulations on Base Erosion and Anti-Abuse Tax (The BEAT)

On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more

32 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide