Stephanie Pindyck Costantino Talks Domestic Oil and Gas M&A with The Deal
Structuring an MLP Finance
Jaffe Sees 'A Lot' of IPOs in 2013 'Pipeline'
Key Points - Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023. Certain...more
The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more
On July 18, the Federal Energy Regulatory Commission (FERC) issued orders (i) adopting procedures to implement the federal corporate income tax rate reduction in natural gas pipeline rates, and (ii) providing guidance...more
On Thursday, March 15, 2018, the Federal Energy Regulatory Commission (“FERC” or “Commission”) issued a series of orders and notices to address changing the treatment of income tax costs in rate setting for oil and natural...more
In a March 15 decision, the Federal Energy Regulatory Commission (FERC) disallowed certain tax benefits for master limited partnerships (MLPs), the predominant corporate structure for several energy companies....more
The effects of the Tax Cuts and Jobs Act are rippling through the energy industry. Our Energy Group explores how the Federal Energy Regulatory Commission considers accounting for the new corporate tax rate and what it could...more
On March 15, 2018, the Federal Energy Regulatory Commission (FERC) issued important orders regarding two significant tax-related rate matters affecting interstate oil and natural gas pipelines. The action eliminated tax...more
On March 15, 2018, the Federal Energy Regulatory Commission (“FERC”) issued an order on remand disallowing an income tax component in cost-of-service rates charged by an interstate oil pipeline owned by a master limited...more
FERC eliminates tax allowance in MLP pipelines’ cost-based rates and establishes procedures to address income tax changes. Key Points: ..FERC will no longer permit MLPs to recover an income tax allowance in cost-based...more
The final version of the proposed Tax Cuts and Jobs Act (the “Act”) was released on December 15, 2017. This legislation, unless amended again, is expected to be voted on this week in the U.S. House of Representatives and the...more
On October 25, 2017, bipartisan legislation aimed at leveling the playing field between renewable and fossil fuels was re-introduced in the Senate and House of Representatives. Senator Chris Coons (D-DE), along with eight...more
On November 2, the House Ways and Means Committee released the Tax Cuts and Jobs Act (the “Act”). The Act is over 400 pages and was accompanied by a section-by-section summary that itself reached 82 pages. The Act is aimed at...more
Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships....more
The number of “Action Items” detailed in the OECD’s report released yesterday to combat base erosion and profit shifting strategies among multinational corporations. The recommendations have drawn criticism from some GOP...more
NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more
On June 24, 2015, the Master Limited Partnership Parity Act (S. 1656) was reintroduced in the House and the Senate. The legislation would provide investors in renewable energy projects with tax breaks that are currently...more
The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...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
On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more
The rise of master limited partnerships (MLPs) as an asset class has coincided with investors’ desire for stable and growing cash flow. In 2013, there were 21 initial public offerings (IPOs) of MLPs and more are on the way in...more
On July 31, 2013, the Senate Finance Subcommittee Energy, Natural Resources, and Infrastructure held a hearing on the Master Limited Partnership Parity Act (S. 765). The bill would extend the master limited partnership (MLP)...more