IRS proposes guidance for determining MLP qualifying income

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www.lexology.com — On May 5, 2015, the Internal Revenue Service (IRS) issued proposed regulations that would provide additional guidance for purposes of interpreting the rules under Internal Revenue Code (IRC) Section 7704(d)(1)(E) relating to the classification of income from certain activities with respect to minerals or natural resources as qualifying income. The proposed regulations were issued in response to increased interest in the application of IRC Section 7704(d)(1)(E) and will affect publicly traded partnerships (PTPs), master limited partnerships (MLPs) and their partners. The Department of the Treasury (Treasury) and the IRS have requested comments on all aspects of the proposed regulations. Before the proposed regulations are adopted as final regulations, Treasury and the IRS will consider any comments that are timely submitted to the IRS.

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