New rules recently proposed by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) would re-characterize purported debt instruments as equity instruments, and could have significant implications...more
The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more
Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more
The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more
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
Federal excise taxes imposed on natural gas, propane and other alternative fuels can significantly add to their cost and can create a disincentive to their use compared with more traditional fuels such as diesel and gasoline,...more
In This Issue:
- ILPA Guidelines Have Noticeable Impact
- Extracting Tax Value in Debt Refinancings and Modifications
- Private Equity and Venture Capital Investing in China: Exit Strategy and Circular 698
-...more