Following the inauguration, President Trump's Chief of Staff
issued a memorandum implementing a regulatory freeze
common to changes in administration. The freeze withdraws all
unpublished regulations for further review and approval by the new
administration, including the final regulations issued last
Thursday under Section 7704 of the Internal Revenue Code to provide
qualifying income guidance with respect to the natural resource
activities of publicly traded partnerships or "MLPs." The
unpublished
final regulations had been scheduled to be published in the
Federal Register on January 24, 2017.
The timing of any review and approval of the unpublished
regulations is uncertain. For now, the withdrawn final regulations
will go back to the IRS and we'll continue living under the proposed regulations. As a practical matter,
the withdrawn regulations will continue to be relevant to MLPs and
those considering the formation of an MLP. Although the withdrawn
final
