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Inflation Reduction Act
New Holding Period Rules for Carried Interests and the Impact on Upstream Oil and Gas
The Tax Cuts and Jobs Act (the TCJA) modifies the holding period necessary for gains attributable to applicable partnership interests, commonly known as carried interests, to qualify as long-term capital gains, subject to federal income tax at a rate of...
Steady Progress on Tax Regs, but Big Questions Remain
As Congress grapples with a jam-packed legislative calendar and a fraught campaign season looms, most of the near-term movement on the tax front continues to come from the executive branch. The months following the December enactment of the Tax Cuts...
After the Dust Settles: Recapping Certain Tax Reform Provisions Affecting Exempt Organizations
As is well known, on December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Final Bill”) into law. During the course of this massive legislative effort, various provisions affecting tax-exempt organizations were proposed. While receiving less...
The New Partnership Audit Rules, Part 6: The Impact on Purchases and Sales of Partnership Interests
This is the sixth installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
The New Partnership Audit Rules, Part 5: The Pull-In Procedure
This is the fifth installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
Full Slate Means Uncertain Fate for Tax Law Fixes
As the second session of the 115th Congress lurches into summer, legislative prospects for a widely expected technical corrections package remain uncertain. The swift, bipartisan resolution of the so-called “grain glitch” under new Section 199A provided early hope, though it...
Application of Partnership Audit Rules to Private Funds
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the New Rules). Under the New...
The New Partnership Audit Rules, Part 4: The Partnership Representative
This is the fourth installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
IRS Provides Issuers Of Tax-Advantaged Debt with New "DIY" Tools to Fix Nonqualified Use
On April 11, 2018, the IRS released Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), which provides an expansion of the remedial actions available to issuers of tax-advantaged bonds. Specifically Rev. Proc. 2018-26 provides: Additional options for issuers seeking to remediate private...
The New Partnership Audit Rules, Part 3: The Push-Out Election
This is the third installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
Differing Objectives and Consequences of Recent MLP Conversions to Corporations
In recent weeks, two more master limited partnerships (MLPs) have announced their intention to convert to corporations for federal income tax purposes. Such transactions will take different forms and are driven by different considerations, including, in large part, tax considerations...
The New Partnership Audit Rules, Part 2: The Election Out
This is the second of several installments of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of...
Financing Renewable Energy Projects: The Interest Deductibility Limitation
As we have previously discussed (please see here for a more detailed discussion), the Tax Cuts and Jobs Act (TCJA) limits a taxpayer’s interest deductions in a taxable year to the sum of (A) the taxpayer’s business interest income for...
Keeping Up the BEAT: Offset Outlook Beyond 2025
One of the more pronounced quirks of the Tax Cuts and Jobs Act (TCJA) is the law’s deliberately staggered schedule. Within five to eight years a broad range of provisions are slated to expire, phase down, or ramp up in...
Treasury and IRS Issue Guidance Concerning Carried Interests Held Through S-Corporations
On March 1, 2018, the Treasury Department and the IRS issued an advanced version of Notice 2018-18, stating that forthcoming Treasury regulations would provide that applicable partnership interests, commonly referred to as carried interests, held by S-corporations will be subject...