ETFdb Logo
ETFdb Logo
  • ETF Database
  • Channels
    • Themes
      • Active ETF
      • Artificial Intelligence
      • Beyond Basic Beta
      • China Insights
      • Climate Insights
      • Core Strategies
      • Crypto
      • Disruptive Technology
      • Energy Infrastructure
      • ETF Building Blocks
      • ETF Investing
      • ETF Education
      • ETF Strategist
      • Financial Literacy
      • Fixed Income
      • Free Cash Flow
      • Innovative ETFs
      • Institutional Income Strategies
      • Leveraged & Inverse
      • Managed Futures
      • Market Insights
      • Modern Alpha
      • Multifactor
      • Responsible Investing
      • Retirement Income
      • Tax Efficient Income
    • Asset Class
      • Equity
        • U.S. Equity
        • Int'l Developed
        • Emerging Market Equities
      • Alternatives
        • Commodities
        • Gold/Silver/Critical Minerals
        • Currency
        • Volatility
      • Fixed Income
        • Investment Grade Corporates
        • US Treasuries & TIPS
        • High Yield Corporates
        • Int'l Fixed Income
    • ETF Ecosystem
    • ETFs in Canada
  • Tools
    • ETF Screener
    • ETF Country Exposure Tool
    • ETF Sector Tracker Tool
    • ETF Database Categories
    • Head-To-Head ETF Comparison Tool
    • ETF Stock Exposure Tool
    • ETF Issuer Fund Flows
    • Indexes
    • Mutual Fund To ETF Converter
  • Research
    • ETF Education
    • Equity Investing
    • Dividend ETFs
    • Leveraged ETFs
    • Inverse ETFs
    • Index Education
    • Index Insights
    • Top ETF Sectors
    • Top ETF Issuers
    • Top ETF Industries
  • Webcasts
  • Themes
    • AI ETFs
    • Blockchain ETFs
    • See all Thematic Investing ETF themes
    • ESG Investing
    • Marijuana ETFs
  • Multimedia
    • ETF 360 Video Series
    • ETF of the Week Podcast
    • ETF Prime Podcast
    • Video
  • Company
    • About VettaFi
    • Get VettaFi’ed
  • PRO
    • Pro Content
    • Pro Tools
    • Advanced
    • FAQ
    • Pricing
    • Free Sign Up
    • Login
  1. Index Insights
  2. Monday Mailbag: Taxman
Index Insights
Share

Monday Mailbag: Taxman

Maria HalmoSep 21, 2014
2014-09-21

I heard that the government is no longer allowing new MLPs. Is this true?

A lot of people write headlines to sell papers. What actually happened is that on March 28th, the IRS released a statement indicating that it would pause in the issuance of new MLP private letter rulings (PLRs) related to qualifying income. Previous to that time, there had been eight new PLRs issued in 2014. (There have been 14 in total during 2014, but we’ll get to that in a bit.)

We ran some quick calculations and realized that the IRS issued 28 PLRs in 2013, versus 12 in 2012, and less than five a year in 2009 through 2011. So, we figured they were just ready for a vacation.

Nope. Rather than going on vacation, the IRS is actually working harder. Looking back, a lot of those PLRs in 2012 and 2013 concerned non-traditional business models including but not limited to the disposal of fracking water and fluids, the mining, marketing, and processing of sand and proppants used in hydraulic fracturing, refining, and even offshore drilling. Since then, the industry has seen a significant increase in the IPOs of a diverse range of businesses.

2014.09.22 Mailbag IPO Chart

On May 1st, an IRS employee noted during a panel discussion that the IRS will continue to issue PLRs for “down the middle” oil and gas businesses, which we interpret to mean pipeline and storage companies. The pause remains for the businesses that support hydraulic fracturing and others “outside the fairway” until the IRS can develop a standardized method of consideration. While the original review was expected to be complete in two to three months, there is now no estimate on timing.

This makes sense, given that six of the 14 PLRs issued this year have come after the pause was announced. All of the ones issued this year were submitted during the spring and summer of 2013, so the IRS has continued to work through their backlog. The last PLR was issued on May 16th.

On August 26th, the Treasury Department and the IRS issued their 2014-2015 Priority Guidance Plan. On page 22, the eighteenth and final item under partnerships is “Guidance under §7704(d)(1)(E) regarding qualifying income for publicly traded partnerships.” We do expect formal guidance to be issued eventually, but so far, no indication has been given as to what that guidance is (or when to expect it).


Content continues below advertisement

» Popular Pages

  • Tickers
  • Articles

Oct 03

Four ETFs for Consistent Income in Equities

Oct 03

ETF Prime: Hendrickson and Edmondson on EQM Indexes Plus Thematic Investing

Oct 03

Sovereign’s Fund Invests in "Most Spiritually Integrated" Companies

Oct 03

Navigating a 401(k) Rollover

Oct 03

Treasuries Grab the Wheel

Oct 03

An Upside in Equal-Weight ETF SDOG

Oct 03

Dollar Dollar Bill, Y'all!

Oct 03

Top 5 Active ETFs Beating Rivals on Fees

Oct 03

Once in a Decade Opportunity to Diversify Away From the “Magnificent 7”

Oct 03

Top Performing Leveraged/Inverse ETFs: 10/01/2023

QQQ

Invesco QQQ Trust Series I

SPY

SPDR S&P 500 ETF Trust

VOO

Vanguard S&P 500 ETF

JEPI

JPMorgan Equity Premium...

TLT

iShares 20+ Year Treasury...

SCHD

Schwab US Dividend Equity ETF...

TSLY

YieldMax TSLA Option Income...

SMH

VanEck Semiconductor ETF

VTI

Vanguard Total Stock Market...

VGT

Vanguard Information...

Loading Articles...
Our Sites
  • VettaFi
  • Advisor Perspectives
  • ETF Trends
Tools
  • ETF Screener
  • Mutual Fund to ETF Converter
  • Head-To-Head ETF Comparison
  • ETF Country Exposure Tool
  • ETF Stock Exposure Tool
  • ETF Database Pro
More Tools
  • Financial Advisor & RIA Center
Explore ETFs
  • ETF News
  • ETF Category Reports
  • Premium Articles
  • Alphabetical Listing of ETFs
  • Browse ETFs by ETF Database Category
  • Browse ETFs by Index
  • Browse ETFs by Issuer
  • Compare ETFs
Information
  • Contact Us
  • Terms of Use and Privacy Policy
  • © 2023 VettaFi LLC. All rights reserved.

Advertisement

Is Your Portfolio Positioned With Enough Global Exposure?

ETF Education Channel

How to Allocate Commodities in Portfolios

Tom LydonApr 26, 2022
2022-04-26

A long-running debate in asset allocation circles is how much of a portfolio an investor should...

Core Strategies Channel

Why ETFs Experience Limit Up/Down Protections

Karrie GordonMay 13, 2022
2022-05-13

In a digital age where information moves in milliseconds and millions of participants can transact...

}
X