On August 3, 2015, TEI submitted comments to the IRS on proposed regulations (REG-132634-14) relating to qualifying income from activities of publicly traded partnerships with respect to minerals or natural resources. The Institute’s comments focused on how the proposed regulations fail to capture the complex processes and activities carried on by publicly traded partnerships and, as a result, propose rules that are inconsistent with section 7704(d)(1)(E) and its legislative history as previously interpreted and applied by the IRS in 27 years of ruling practice. TEI recommended, among other things, that the IRS consult directly with industry experts and adversely impacted taxpayers before finalizing the proposed regulations.
TEI's comments were prepared under the aegis of TEI's Federal Tax Committee, whose chair is Katrina Welch. Patrick Evans, TEI’s Chief Tax Counsel, coordinated the preparation of TEI's