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
1/26/2017
/ Final Rules ,
IRS ,
Minerals ,
Moratorium ,
Natural Gas ,
Natural Resources ,
Oil & Gas ,
Partnerships ,
Pass-Through Entities ,
Qualifying Income ,
Regulatory Freeze ,
U.S. Treasury
On October 5, 2016, the Treasury Department and Internal Revenue Service (“IRS”) published much-anticipated final, temporary and new proposed regulations providing guidance under Internal Revenue Code sections 707 and 752 on...more
On November 2, 2015, President Obama signed into law the Bipartisan Budget Agreement of 2015 (the “Act”), which includes major changes to the partnership tax audit rules (the “New Audit Rules”). The Act repeals the current...more
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
7/30/2015
/ Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Managers ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Safe Harbors ,
Section 409A ,
Section 457A ,
Significant Entrepreneurial Risk (SER) ,
U.S. Treasury
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
Following a year long pause, the IRS announced Friday that it has resumed its review of pending private letter ruling (PLR) requests and is accepting new PLR requests concerning MLP qualifying income under Section...more