On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more
7/9/2025
/ Alternative Minimum Tax ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
International Tax Issues ,
New Legislation ,
OECD ,
Oil & Gas ,
Qualified Business Income ,
Research and Experiment Tax Credit ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Reform
As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more
For more than twenty years, the North American Free Trade Agreement (“NAFTA”), and later, the United States‑Mexico-Canada Agreement (“USMCA”), have facilitated cross-border trade and investment among the United States,...more
2/13/2025
/ Canada ,
Energy Policy ,
Energy Sector ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
NAFTA ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice. However, taxpayers and their advisors wishing for a repeal of the corporate alternative minimum tax in 2025...more
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate...more
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more
On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more
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
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
10/10/2023
/ Artificial Intelligence ,
Audits ,
Enforcement ,
General-Business ,
Hedge Funds ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Master Limited Partnerships ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Real Estate Transactions ,
Tax Litigation
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
9/8/2023
/ Carbon Capture and Sequestration ,
Environmental Social & Governance (ESG) ,
IRS ,
Leases ,
MLPs ,
Partnerships ,
Private Letter Rulings ,
Qualifying Income ,
Real Estate Investments ,
REIT ,
Shareholders ,
Taxable Income
On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum...more
On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes an excise tax on certain repurchases...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
2/5/2020
/ Asset Management ,
Capital Formation ,
Capital Markets ,
Continuing Legal Education ,
Energy Sector ,
Equity ,
Events ,
IRS ,
Midstream Contracts ,
MLPs ,
REIT ,
Tax Planning