Baker Botts tax lawyers provide innovative solutions that address thorny questions relating to the allocation of taxable income and tax benefits, distribution mechanics, the proper role of capital accounts and recourse and nonrecourse debt allocations, the application of disguised sale rules, the structuring of mixing bowl transactions and the structuring and issuance of compensatory profits interests in partnerships to management and employees.
We routinely answer complex formation, allocation and distribution questions that arise under partnership and limited liability company (LLC) agreements and counsel clients on the prudence of using partnerships, LLCs and other flow-through structures to assist with their business objectives.
Our lawyers have extensive experience in the formation, structuring and taxation of, and tax law requirements applicable to, publicly traded partnerships (MLPs), including the structuring of the movement of assets and entities needed to implement the formation and IPO of the MLP, tax efficient monetization strategies in connection with IPOs of MLPs, issues related to merger and acquisition transactions involving MLPs, and qualifying income and activity issues of MLPs. We also have deep experience with the use of flow-through vehicles for the acquisition, development and operation of oil and gas assets from the perspectives of the operator, working interest investor and royalty owner.
IRS Releases Second Set of Proposed Regulations Clarifying Rules for Investments in "Qualified Opportunity Funds" Under 2017 Tax Reform ActClient Updates
IRS Releases First Set of Proposed Regulations Clarifying Rules for Investments in "Qualified Opportunity Funds" under 2017 Tax Reform ActClient Updates
IRS Provides Interim Guidance Regarding Withholding Obligations with Respect to Dispositions of Interests in PartnershipsClient Updates
Baker Botts Event for Women in Tax, Featuring Heather Crowder, Phillips 66, VP and General Tax Officer
Please join the women in tax at Baker Botts for the final virtual networking event of 2021 designed for women in-house tax professionals on Monday, December 13 from 11:00 a.m. - 12:30 p.m. CT.
Please join the women in tax at Baker Botts for the the second of our networking events designed for women in-house tax professionals on Thursday, August 26 from 12:00 p.m. - 1:30 p.m. CT.
Please join the women in tax at Baker Botts LLP for the first of our networking events designed for women in-house tax professionals on March 4 at 10:30 a.m. CT.