News & Analysis as of

U.S. Treasury Master Limited Partnerships

Vinson & Elkins LLP

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more

Bracewell LLP

Final Regulations and New Proposed Regulations on Immediate Expensing: Implications for Energy and Infrastructure

Bracewell LLP on

On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more

Akin Gump Strauss Hauer & Feld LLP

Final Regulations on MLP Qualifying Income Provide Clarification

Final regulations issued by the Treasury and the Internal Revenue Service (IRS) on January 19, 2017, revealed a set of new rules interpreting “qualifying income” under Section 7704(d) of the Internal Revenue Code, affecting...more

Orrick, Herrington & Sutcliffe LLP

Midnight Regulations Provide Oil & Gas MLPs with Favorable Answers; New Administration Immediately Withdraws

On January 19, 2017, less than 24 hours before the change of administration, the IRS and Treasury released much-anticipated final regulations under Code section 7704(d)(1)(E) setting parameters for qualifying income for...more

Akin Gump Strauss Hauer & Feld LLP

New Partnership Liability and Disguised Sale Regulations

Key Points - - Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more

Latham & Watkins LLP

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

Latham & Watkins LLP on

IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing. “I’m mad as Hell, and, frankly, I’m not going to take it anymore.” — Paraphrase of concerned citizen and...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

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

Eversheds Sutherland (US) LLP

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

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

Porter Hedges LLP

News Alert: "Treasury Department Issues MLP Proposed Regulations on Qualifying Income"

Porter Hedges LLP on

On Wednesday (May 6th, 2015), the Treasury Department published proposed regulations under Section 7704(d)(1)(E) of the Internal Revenue Code that define qualifying activities of publicly-traded partnerships with respect to...more

Bracewell LLP

MLP Qualifying Income – Treasury and IRS Issue Proposed Regulations

Bracewell LLP on

On May 5, 2015, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations that provide much-anticipated guidance on the scope of qualifying income under Section 7704(d)(1)(E) of the...more

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