IRS Again Considering MLP Private Letter Rulings

The Internal Revenue Service has ended its year-long moratorium on issuing MLP qualifying income rulings under Section 7704 of the tax code. 

In an announcement made today at the Federal Bar Association Tax Law Conference in Washington, the IRS indicated that "workable standards" have been developed that will allow work to begin immediately on those letter ruling requests filed during the pause and we can expect that proposed regulations will soon be issued covering natural resource-related "services provided by contractors to others." 

Although we don't have anything more specific on substance or timing at this point, we understand that these standards will be incorporated into the ruling process and that the IRS will continue to issue qualifying income rulings while the regulation project continues. Stay tuned.