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IRS and Treasury Finalize Guidance Determining MLP Qualifying Income

Regulations provide rules for determining MLP qualifying income from certain mineral or natural resource-related activities and services. On January 19, 2017, the US Department of the Treasury (Treasury) and the Internal...more

IRS Tightens Rules on Disguised Sales and Allocating Partnership Liabilities

New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions. On October 4, 2016, the Internal Revenue Service (IRS)...more

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

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

IRS Proposes Guidance for Determining MLP Qualifying Income

Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources. On May 5, 2015, the Internal Revenue...more

IRS Presses Play on MLP Private Letter Rulings

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

3/9/2015  /  IRS , MLPs , Private Letter Rulings
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