Alison Chen and Montel Jackel Quoted in Tax Notes Today on Questions Regarding Regulatory Freeze Memo
Tax Notes Today has quoted Akin Gump tax partner Alison Chen and senior counsel Monte Jackel in the article “Clarification Needed on PTP and Dividend Equivalents Regs,” which reports on the possible contradictory nature between a White House memo calling for a regulatory freeze and final regulations that appeared in the Federal Register. The article says the primary question pertains to dividend equivalents and publicly traded partnership (PTP) regulations.
Jackel said practitioners are in a difficult spot in advising clients because of the potential for uncertainty about the regulations’ future. There needs to be public clarification, he said, as to whether the regulations were published in accordance with the terms of the freeze memo.
Chen said the final regulations are particularly important to master limited partnerships (MLPs). Many of the changes, she noted, are MLP-friendly, yet “everyone thought the final regulations would be withdrawn pursuant to the Priebus memo. We were caught by surprise when they were published in the Federal Register as scheduled.” She added, “It would be a big disappointment to all if rules ultimately return to the approach of the proposed regulations.”