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COVID-19 Tax Update: Tax Return Filing and Tax Payment Relief

Last week, in a pair of notices released under President Trump’s March 13, 2020 Emergency Declaration relating to the coronavirus pandemic, the IRS and the Treasury Department offered relief for tax return filing and tax...more

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

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

Bracewell Tax Report - January 2019

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Bracewell Tax Report - November 2018

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Application of Partnership Audit Rules to Private Funds

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more

Treasury and IRS Release Final Regulations on Qualifying Income, but Halted by Trump Moratorium

January 25, 2017 On January 19, 2017, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding qualifying income under Internal Revenue Code (Code) section...more

Proposed IRS Regulations Target Management Fee Waiver Arrangements

On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more

MLP Qualifying Income – Treasury and IRS Issue Proposed Regulations

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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