The Rising Influence of Rising Affluence

[DewDiligence]

This could affect Casablanca’s plans for CLF, which include placing the US assets in an MLP:

http://online.wsj.com/news/articles/SB10001424052702303873604579491750855855862

The MLP structure, which allows companies to forgo paying corporate income taxes, has long been used by pipeline operators and other energy-logistics outfits to raise capital. But a crush of new inquiries from tangential businesses, including water recyclers and sand mines, has given the agency pause…

The IRS is stepping back from issuing so-called "private-letter rulings"—the guidance it provides to companies that want to know whether their line of business meets the requirements to be treated as a tax-exempt partnership—so it can conduct an internal review of its process. The agency said the halt is temporary, but it has given no timeline for when new approval letters will be issued.

Several tax lawyers said the government wants to make sure it hasn't opened the door too wide.