The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
In a new Revenue Ruling, the IRS addresses the scope, ownership, and placed-in-service date for carbon capture equipment.
Key Points:
..Developers adding carbon capture equipment to an existing industrial facility now...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
Regulations provide rules for determining MLP qualifying income from certain mineral or natural resource-related activities and services.
On January 19, 2017, the US Department of the Treasury (Treasury) and the Internal...more
New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions.
On October 4, 2016, the Internal Revenue Service (IRS)...more
Tax partnerships, including MLPs, seeking to restructure debt face peril and possibility during challenging times.
With the lowest oil prices in more than a decade and the equity markets effectively closed to them, oil...more
A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures.
On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more
IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing.
“I’m mad as Hell, and, frankly, I’m not going to take it anymore.”
— Paraphrase of concerned citizen and...more
10/9/2015
/ Commodities ,
Energy Sector ,
Exploration and Production Assets ,
IRS ,
Liquid Natural Gas ,
Marketing ,
Master Limited Partnerships ,
Mineral Exploration ,
Mineral Leases ,
Minerals ,
Oil & Gas ,
Passive Activity ,
Pipelines ,
Private Letter Rulings ,
Qualifying Income ,
Surface Transportation ,
U.S. Treasury ,
Underground Injection Wells
Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources.
On May 5, 2015, the Internal Revenue...more
IRS announces end of moratorium on MLP letter ruling requests.
The IRS has resumed the ruling process for private letter ruling (PLR) requests regarding qualifying income issues for MLPs under section 7704. An official...more
The market’s notable uptick in MLP-to-MLP M&A activity, often preceded by an acquisition of the target MLP’s general partner, follows a trend we recently identified.
At least five MLP M&A transactions have been...more
MLP merger and acquisition activity can take a number of different forms to unlock value for sponsors and unitholders.
Background -
In the first half of 2014, master limited partnership (MLP) mergers and...more
The UP-C structure — which offers tax benefits to pre-IPO investors and sponsors — likely will expand among energy companies.
In 2013, several energy companies went public using a so-called UP-C structure. In using...more
Offshore MLPs can provide a tax efficient vehicle for investors, but only if structured properly.
A master limited partnership (MLP) is a partnership or limited liability company traded on a stock exchange that...more