Linda Carlisle Quoted Regarding Proposed PTP Regulations

"Officials Indicate Unwillingness to Scrap PTP Exclusive List"
Tax Analysts
10.02.15Linda Carlisle was quoted regarding proposed publicly traded partnership (PTP) regulations discussed by Treasury and IRS officials on October 1, 2015. The proposed regulations, promulgated May 6, 2015, would impose new restrictions, which are inconsistent with a number of outstanding private letter rulings (PLRs), on the types of activities that produce qualifying income for purposes of determining whether a PTP will be taxed as a partnership. The proposed regulations would allow PTPs that received PLRs that are inconsistent with the final regulations a 10-year transition period. Ms. Carlisle asked how a taxpayers would be able to know whether their PLR was inconsistent with the final regulations. Curtis Wilson, IRS Associate Chief Counsel for Passthroughs and Special Industries, replied that determining how best to let people know is under consideration. Tom West, Tax Legislative Counsel, said that he hoped that the standards in any final regulations would be so clear that taxpayers could rely on opinions of counsel re the status of any outstanding PLRs.
Related Files
Related Links