On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
10/10/2023
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Audits ,
Enforcement ,
General-Business ,
Hedge Funds ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Master Limited Partnerships ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Real Estate Transactions ,
Tax Litigation
Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more
9/8/2023
/ Carbon Capture and Sequestration ,
Environmental Social & Governance (ESG) ,
IRS ,
Leases ,
MLPs ,
Partnerships ,
Private Letter Rulings ,
Qualifying Income ,
Real Estate Investments ,
REIT ,
Shareholders ,
Taxable Income
In the early 1990s, several MLPs converted into REITs to take advantage of better capital formation opportunities, but the REIT structure was not suitable for many midstream assets. Recent IRS guidance suggests this historic...more
2/5/2020
/ Asset Management ,
Capital Formation ,
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Continuing Legal Education ,
Energy Sector ,
Equity ,
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IRS ,
Midstream Contracts ,
MLPs ,
REIT ,
Tax Planning