The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket options has been gathering steam over the past few years.
This Legal Update is the second in a series that
Mayer Brown Tax lawyers are publishing on key
developments at the national and international
levels related to the Organisation for Economic
Co-Operation and Development痴 ("OECD")
Action Plan on Base Erosion and Profit Shifting
(the "BEPS Action Plan").
A Master Limited Partnership or MLP (sometimes called a publicly traded partnership or PTP), is an attractive business entity because it is treated as a partnership for federal income tax purposes even though the ownership interests in the MLP are publicly traded.
The Organisation for EconomicCoordination and Development released its highly anticipated Action Plan on Base Erosion and Profit Shifting, which was then unanimously approved by the G-20 Finance Ministers at their July 20, 2013 meeting in Moscow.