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Proposed Changes to Code Section ‎‎1061 Contemplate Significant Changes for Real Estate Funds ‎and Developers

The “Inflation Reduction Act of 2022” recently announced by Senators Manchin and Shumer to be added to the 2022 Budget Reconciliation bill proposes several significant changes to Section 1061 of the Internal Revenue Code of...more

Proposed Legislative Extension of Investment Tax Credits for Energy ‎Storage Technologies

On March 9, 2021, a bipartisan group of federal lawmakers introduced the “Energy Storage Tax Incentive and Deployment Act of 2021” (the “Act”) which is intended to extend certain investment tax credits to standalone energy...more

IRS Issues Final Regulations on Partnership Carried Interests

On January 13, 2021, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued the official version of Final Treasury Regulations (the “Final Regulations”) providing guidance under the “carried...more

IRS Issues Carried Interest Guidance

On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more

CARES Act Guide: Overview of IRS Guidance Regarding the Employee Retention Credit

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) was signed into law on March 27, 2020. Section 2301 of the CARES Act provides for a refundable payroll tax credit (the “Retention Credit”) for 50% of...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “C” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “C” corporation borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Lender Considerations Supplement

Distressed economic climates can produce unique circumstances for a lender. As a borrower defaults on payments or breaches financial covenants, a lender may reexamine its tax reporting around the borrower’s debt (e.g.,...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – Partnership Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues partnership borrowers may face in debt restructurings. As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn – “S” Corporation Considerations Supplement

The discussion in this Quick Study Supplement outlines select federal income tax issues “S” corporation borrowers may face in debt restructurings.1 As noted in our debt restructuring overview Quick Study, a borrower generally...more

Federal Income Tax Considerations for Debt Workouts During an Economic Downturn

As the economic impact of COVID-19 continues to evolve, many businesses are looking to restructure their debt to help navigate through the crisis. In the past several weeks, lenders have been inundated with such requests,...more

CARES Act Guide: Overview of IRS Guidance Allowing Partnerships to File Amended Returns

On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) into law. In part, the CARES Act provides certain retroactive tax relief for taxpayers for the taxable years...more

IRS Guidance Regarding Waiver Of Penalties And Acquiring Advance Payments For Payroll Tax Credits

On March 18, 2020 President signed the Families First Coronavirus Response Act, or the “FFCRA”, into law. On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act, or the “CARES Act”,...more

UPDATE: CARES Act Guide: Overview of Key Business Tax Provisions

On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act or the “CARES Act”, into law. The CARES Act will provide significant financial relief to individuals and small businesses,...more

The Midstream REIT; New Private Letter Ruling Guidance from the IRS May Enhance REIT Investment Option for Midstream Energy Assets

Private letter ruling 201907001 (the “PLR”), recently issued by the Internal Revenue Service (“IRS”), indicates that a midstream energy company may be able to organize as a real estate investment trust (“REIT”) under Section...more

2/24/2020  /  Internal Revenue Code (IRC) , IRS , REIT , UBIT

Tracking Tax Reform: The Impact on MLPs of the House and Senate Conference Report on the Tax Cut and Jobs Act

On December 15, the House and Senate Conference Committee released the conference report on the Tax Cuts and Jobs Act (the “Conference Committee Report” or “Report”), containing the specific details on the tax plan they hope...more

The Proposed Tax Cuts and Jobs Act and MLPs

On November 2, the House Ways and Means Committee released the Tax Cuts and Jobs Act (the “Act”). The Act is over 400 pages and was accompanied by a section-by-section summary that itself reached 82 pages. The Act is aimed at...more

IRS Releases Final Treasury Regulations on MLP Qualifying Income

On January 24, 2017, the Internal Revenue Service (IRS) issued final regulations addressing master limited partnership (MLP) qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code (the Code). The...more

Locke Lord QuickStudy: Proposed Regulations Issued on MLP Qualifying Income

The Internal Revenue Service (IRS) recently issued proposed regulations addressing master limited partnership (MLP) qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code. This Locke Lord QuickStudy...more

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