Qualifying Services under IRC 7704

IRS Private Letter Ruling 201213004 This letter responds to a letter dated May 25, 2011, and subsequent correspondence by X’s authorized representative, requesting rulings under § 7704 of the Internal Revenue Code on behalf of X. FACTSThe information submitted states that X is a State limited liability company that elected to be classified as an association for federal […]

Qualifying Income of a Publicly Traded Partnership under IRC 7704

Private Letter Ruling 201206004 This responds to a letter dated June 3, 2011, submitted on behalf of Company, and subsequent correspondence, requesting a ruling concerning the qualifying income exception to the publicly traded partnership rules of § 7704 of the Internal Revenue Code. FACTSCompany is a limited partnership organized under the laws of State.  Company is a “publicly traded […]

Michigan: Revised Notice on Michigan Business Tax Treatment of Disregarded Entities Reflects Recently Enacted Legislation

State Tax Matters: Income/Franchise: Notice to Taxpayers Regarding Federally Disregarded Entities and the Michigan Business Tax, Mich. Dept. of Treas. (issued 11/29/10; revised 4/30/11; revised 10/3/11; revised 11/15/11; revised 1/26/12). The department has once again updated its notice on the Michigan Business Tax (MBT) treatment of federally disregarded entities to include legislative amendments that were […]


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