The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
In a new Revenue Ruling, the IRS addresses the scope, ownership, and placed-in-service date for carbon capture equipment.
Key Points:
..Developers adding carbon capture equipment to an existing industrial facility now...more
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
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
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
10/9/2015
/ Commodities ,
Energy Sector ,
Exploration and Production Assets ,
IRS ,
Liquid Natural Gas ,
Marketing ,
Master Limited Partnerships ,
Mineral Exploration ,
Mineral Leases ,
Minerals ,
Oil & Gas ,
Passive Activity ,
Pipelines ,
Private Letter Rulings ,
Qualifying Income ,
Surface Transportation ,
U.S. Treasury ,
Underground Injection Wells
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 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
MLP merger and acquisition activity can take a number of different forms to unlock value for sponsors and unitholders.
Background -
In the first half of 2014, master limited partnership (MLP) mergers and...more