Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more
In the early 1990s, several MLPs converted into REITs to take advantage of better capital formation opportunities, but the REIT structure was not suitable for many midstream assets. Recent IRS guidance suggests this historic...more
On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more
Can private equity firms unwittingly trigger a tax when they invest in distressed assets? A: All taxpayers, including private equity firms, can trigger a tax when investing in distressed assets. This can occur when a...more
Following a year long pause, the IRS announced Friday that it has resumed its review of pending private letter ruling (PLR) requests and is accepting new PLR requests concerning MLP qualifying income under Section...more
IRS announces end of moratorium on MLP letter ruling requests. The IRS has resumed the ruling process for private letter ruling (PLR) requests regarding qualifying income issues for MLPs under section 7704. An official...more
In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more