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Media Alert - Baker Botts Comments on New Private Letter Rulings on Qualifying Income

HOUSTON, September 7, 2016 - On September 2, 2016 the Internal Revenue Service (IRS) released two new private letter rulings (PLRs) providing guidance on Master Limited Partnership (MLP) qualifying income under I.R.C. § 7704, one on regasification of LNG, another on interest rate swaps and similar hedging transactions. 

These two rulings come after an August 12, 2016 PLR dealing with an MLP providing fluid handling services to oil and natural gas producers.
Baker Botts partners, Mike Bresson and Steve Marcus are available to comment.
“The new rulings provide only limited insight into the IRS’s current interpretation of the MLP qualifying income rules,” said Mike Bresson, Tax partner at Baker Botts. “We will know much more when the IRS releases new regulations on the topic, which may happen soon.”

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