Linda Carlisle Comments on Qualifying Income Requirement for PTPs in Tax Analysts

"IRS Undecided on Key Issues in PTP Natural Resource Regs"
Tax Analysts
11.12.15Linda Carlisle commented on the need for guidance for purposes of determining whether a PTP satisfies the qualifying income requirements in section 7704. Carlisle said that a lack of guidance under section 7704 meant practitioners frequently asked the IRS to rule on whether a PTP had qualifying income under section 7704(d)(1)(E) from the exploration, development, mining or production, processing, refining, transportation or marketing of any mineral or natural resource.
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