The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more
The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more
6/22/2017
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
TEFRA ,
Trump Administration ,
U.S. Treasury
The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more
Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the “Code’), providing for the use of the net asset value (“NAV”) accounting method for transactions in money market fund...more
7/26/2016
/ Accounting Methods ,
Excise Tax ,
Final Rules ,
Floating NAV ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Company Act of 1940 ,
IRS ,
Money Market Funds ,
NAV ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more
6/24/2015
/ Corporate Taxes ,
Double Taxation ,
Energy Projects ,
Energy Sector ,
Fracking ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Partnerships ,
Master Limited Partnerships ,
Mining ,
Natural Gas ,
Oil & Gas ,
Partnerships ,
Passive Activity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Qualifying Income ,
Research and Development
Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more