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To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

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Saturday, July 10, 2010

Taxation of Publicly Traded Partnerships: SubChapter K Tax: irs private letter ruling 201025037 - qualifying income under 7704(d)

Taxation of Publicly Traded Partnerships: SubChapter K Tax: irs private letter ruling 201025037 - qualifying income under 7704(d): "'This letter responds to a letter dated ----------------------, submitted on behalf of X,�requesting a ruling that income derived from providing marine services to facilitate the�berthing of liquefied natural gas (LNG) tankers that call on X’s LNG receiving terminal is�qualifying income within the meaning of � 7704(d)(1)(E) of the Internal Revenue Code'"
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