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Publicly Traded Partnership (PTP)

Publicly traded partnership’s income from fluid management services was qualifying income

Publicly traded partnership’s income from fluid management services was qualifying income

PLR 201608011 IRS has privately ruled that the gross income of a publicly traded partnership (PTP) from its fluid management and disposal services, and from selling to non-end/retail users filtered hydrocarbons collected as part of the disposal process, was qualifying income under Code Sec. 7704(d)(1)(E). However, the ruling didn’t apply to income derived by the […]

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Ground lease income from cell towers & billboards is qualifying PTP income

Ground lease income from cell towers & billboards is qualifying PTP income

PLR 201250003 In a private letter ruling (PLR), IRS has determined that income earned by a publicly traded partnership (PTP) from ground leases of land and rooftops on which cell phone towers, billboards, internet installations, wind turbines and solar arrays are built qualified as rents from real property under Code Sec. 856(d), and thus was […]

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Prop Regs Would Clarify When Mining, etc. Income is “Qualifying Income” Under PTP Rules

Prop Regs Would Clarify When Mining, etc. Income is “Qualifying Income” Under PTP Rules

Preamble to Prop Reg 05/05/2015; Prop Reg § 1.7704-4   IRS has issued proposed regs under Code Sec. 7704(d)(1)(E) that would clarify when income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or natural resources, as well as from certain other related activities, would be considered “qualifying income” to a […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney