Linda Carlisle Comments On Uncertainties in PTP Regs in Tax Notes Today

"IRS Open to Arguments Concerning Manufacturing Under PTP Regs"
Tax Notes Today
05.14.15Linda Carlisle commented on the uncertainty regarding the Internal Revenue Service's (IRS) newly proposed publicly traded partnership (PTP) qualifying income regulations. The government isn't completely set on defending lines it drew in the regulations and interpretation issues remain, particularly regarding treatment of income from the production of olefins and timber byproducts. A government official has made clear that there is no plan yet to revoke private letter rulings. Carlisle said that while the IRS may not actively revoke any rulings, there are clearly some that will, in effect, be revoked after the transition period ends if the regulations are finalized as is.
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