Linda Carlisle's IRS Comment Letter Reprinted in Tax Notes Today

"PTPs Raise Concerns With Proposed Qualifying Income Regs"
Tax Notes Today
08.05.15Linda Carlisle's comment letter to the Internal Revenue Service (IRS) was reprinted in Tax Notes Today. Carlisle, who represents the National Association of Publicly Traded Partnerships, submitted comments on behalf of NAPTP on proposed regulations under section 7704(d)(1)(E) relating to qualifying income from the exploration, mining or production, processing, refining, transportation and marketing of minerals or natural resources. In the letter, she says proposed publicly traded partnership qualifying income regulations "(i) do not reflect the dynamic nature of the enumerated activities because they set forth an 'exclusive list' of the operations that comprise each activity; (ii) set forth very restrictive definitions of processing and refining without statutory support; and (iii) abandon certain standards utilized by the [IRS] in issuing private letter rulings ... since 1987."
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