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This document is a final regulation issued by the IRS that provides guidance on the definition of domestically controlled qualified investment entities. The regulations primarily affect foreign persons who own stock in a qualified investment entity that would be a United States real property interest if it were not domestically controlled. The regulations address the treatment of qualified foreign pension funds and determine when foreign persons are considered to hold stock in a qualified investment entity. The document also discusses the Treasury Department and IRS's determination regarding the domestic corporation look-through rule and the interpretation of the term "indirectly" in section 897(h)(4)(B). The regulations aim to provide clarity and minimize economic impact. [Extracted from the article]

The article focuses on Drew Wilkerson, CEO of RXO, a newly independent logistics company, who oversees operations arranging shipping for over 100,000 carriers. Wilkerson, a public relations graduate, emphasizes the importance of strong work ethics, listening, and building relationships in the industry, as RXO aims to serve major clients such as Costco, Ford, GM, and Lowe's.

Vanguard, the second-largest money manager in the US, has announced new fees and changes to its customer agreement. Among the new fees is a $25 charge for using the firm's phone service to trade Vanguard mutual funds or exchange-traded funds. Other new fees include a $100 account-closure fee for accounts under $5 million and fees for services that some brokers may provide for free. Vanguard has faced criticism for its customer service, but the company says it has been investing in improving its digital experience for customers. The new CEO, Salim Ramji, will be tasked with deciding the level of customer service to provide. [Extracted from the article]

The article explores Mark L. Reichman's perspective on the metals and mining sector, emphasizing Noble Capital Markets' unique approach to covering various metals and early-stage exploration companies. Topics include his bullish outlook on gold based on factors like geopolitical uncertainty and increased central bank investments, the impact of industrial metals amid economic shifts, and the significance of critical minerals like lithium and rare earths in the electric vehicle market.

Texas-based USD Partners (USDP) is seeking buyers for its Hardisty Rail Terminal in Alberta, Canada. The company entered into a forbearance agreement with lenders, which requires the sale of the terminal by the end of the year. The terminal is an origination point for Canadian crude oil, which is loaded onto railcars for transport to end markets. The sale does not include the diluent recovery unit (DRU), which is jointly owned by Gibson Energy and US Development Group. USDP acquired the terminal assets in 2022 and has a designed takeaway capacity of approximately 262,500 barrels per day. [Extracted from the article]

TXO Partners, a Texas-based master limited partnership, has agreed to purchase oil assets in Montana and North Dakota for $243 million in cash and 2.5 million common units. The transactions are expected to close in the third quarter of 2024, pending customary closing conditions. This acquisition will increase TXO's production by 4,500 daily barrels of oil equivalent and add 17,000 Mboe of proved developed reserves. TXO believes that these assets align with their expertise and capital allocation strategy and will contribute to cash flow and distributions. [Extracted from the article]

Franklin Templeton plans to merge three closed-ended fossil energy midstream funds into a single combined fund after receiving shareholder approval. The funds to be merged are the ClearBridge Energy Midstream Opportunity Fund (EMO), ClearBridge MLP and Midstream Fund (CEM), and ClearBridge MLP and Midstream Total Return Fund (CTR). EMO will absorb the other two funds, and each vehicle will repurchase up to 50% of its common stock before the merger is completed. The merger aims to generate economies of scale, although the share buyback may reduce the net assets of each fund. The combined vehicle is expected to have total net assets of $679.3 million. [Extracted from the article]

Bill Gross, the co-founder and former chief investment officer of Pacific Investment Management Co., believes that European bonds are becoming more attractive compared to Treasury bonds. This comes after surprising election results in Europe caused market volatility and increased French bond yields. Gross also suggests that the recent election outcomes in Mexico, India, and South Africa can serve as a guide for how the US campaign might impact assets in November. While Gross acknowledges potential problems for the stock market as the economy slows, he still finds certain areas, such as pipeline master limited partnerships and regional bank stocks, attractive. [Extracted from the article]

The article presents an interview with Nicole Lee focuses on ESG analysis and its role in protecting dividends and managing risk. Topics discussed include the definition of ESG investments, the integration of ESG factors in portfolio management, the importance of considering environmental, social, and governance factors, and the increasing attention to diversity, climate change, and regulatory developments in ESG investing.

The article focuses on the options available to foreign intermediaries regarding the transfers of publicly traded partnership (PTP) interests under current guidance. It discusses the withholding requirements for PTP interests under Sec. 1446(f) and the qualified intermediary (QI) agreement. It further explains the different roles of intermediaries, such as withholding QIs, nonwithholding QIs, disclosing QIs, and nonqualified intermediaries (NQIs).

In a recent opinion, the Delaware Supreme Court reversed a Court of Chancery decision that found that a general partner of a master limited partnership (the "Partnership") breached the Partnership's limited partnership agreement (the "Partnership Agreement") when the general partner exercised its contractual call right, which resulted in a monetary damages award of almost $700 million dollars. Under the terms of the Partnership Agreement the general partner of the Partnership (the "General Partner") possessed a call right entitling the General Partner to purchase the Partnership's limited partnerships units that the General Partner and its affiliates did not own if certain conditions precedent were satisfied. The majority opinion reasoned that based upon the express terms of the Partnership Agreement and the General Partner's limited liability company agreement, the authority to determine the acceptability of the opinion was vested in the sole member of the General Partner. [Extracted from the article]

This article from Kiplinger Personal Finance discusses the success of high-yield investments over the past 15 years. It highlights the impressive returns of companies like Apple, Amazon, and Microsoft, as well as various funds and partnerships. Contrary to the belief that high-yield investments are risky or unsustainable, many of these investments have provided consistent interest and dividends while maintaining or increasing their share prices and net asset values. The article emphasizes the success of Ares Capital, Pimco funds, Invesco Senior Income Trust, and other high-payout investments. It concludes that high-yield investments have proven to be profitable and reliable over the long term. [Extracted from the article]

Bill Gross, the co-founder and former chief investment officer of Pacific Investment Management Co., has advised investors to stick to value stocks and avoid tech companies for now. He specifically recommended buying Microsoft Corp. if investors want exposure to the tech sector. Gross made these suggestions as tech companies in the S&P 500 Index are experiencing their worst month since September, while value stocks have seen a smaller decline. Gross also mentioned that the yield on benchmark 10-year Treasuries is moving close to its peak for the year, questioning the appeal of owning bonds. He also mentioned that pipeline master limited partnerships (MLPs) have momentum, but cautioned against overweighting them. The S&P 500 slid on the day Gross made these comments due to concerns about US economic growth and inflation. [Extracted from the article]

The family of an elderly JPMorgan client who lost millions of dollars due to investments made while he was suffering from dementia has faced a setback in their legal battle against the bank. A magistrate judge has recommended that the case be thrown out, stating that the family failed to present legally sound claims that JPMorgan breached any duties. The judge also found that the client's deteriorating cognitive state was not taken advantage of by the bank. The only claim that may proceed to trial is one filed by JPMorgan seeking to dismiss the accusations and recover legal costs. [Extracted from the article]

Bill Gross, the co-founder and former chief investment officer of Pacific Investment Management Co., has warned investors about the "excessive exuberance" in financial markets. Despite the Federal Reserve's aggressive monetary tightening, the S&P 500 Index reached a record high above 5,200. Gross attributes this rally to fiscal deficit spending and enthusiasm for artificial intelligence (AI), which have overridden other factors. He also expresses concerns about the unattractiveness of bonds due to the growing US government deficit. Gross recommends going long on two-year notes and short on five- and 10-year bonds. He also shares his favorite trades in the stock market, such as pipeline master limited partnerships and Western Midstream Partners. However, he advises caution with regional banks until the Fed cuts rates. [Extracted from the article]

INVESTING With their winning combination of low account minimums and affordable access to professional investment and financial-planning advice, robo advisers continue to grow briskly. Rewards from shopping at hundreds of brands are swept into investment accounts, and clients can easily allocate a portion of each paycheck to an account. Review the menu of investment options and the extent to which customers can fiddle with the robo's default portfolios. Customers whose self-tailored portfolios stray too far from their stated investment goals and risk tolerance receive nudges from Wealthfront, which also offers sophisticated tax-loss harvesting and tax-sensitive rebalancing strategies. [Extracted from the article]

The article discusses master limited partnerships (MLPs) in energy and energy derivatives pipelines in the U.S. Topics include a discussion of the taxation of investment in MLPs; the effect of the declining price of oil on investor confidence in MLPs; and recommendations of which pipelines currently have high value and low price.

If a security-required person provides security in an amount equal to the maximum security amount, the permitted deferral amount is the total amount of security-required gain. If a security-required person provides security in an amount equal to the maximum security amount, the permitted deferral Bulletin No. 2021-18 1143 May 3, 2021 amount is the total amount of security-required gain. Application for an eligibility certificate and acceptable security To obtain an eligibility certificate with respect to any security-required gain, a security-required person must submit an application to the IRS. Bulletin No. 2021-18 1131 May 3, 2021 Part IV Notice of Proposed Rulemaking Requirements for Certain Foreign Persons and Certain Foreign-Owned Partnerships Investing in Qualified Opportunity Funds and Flexibility for Working Capital Safe Harbor Plans REG-121095-19 AGENCY: Internal Revenue Service (IRS), Treasury. (C) The security-required person provides security to the IRS in the amount required for the security-required gain for which the security-required person seeks to defer gain under section 1400Z-2(a). [Extracted from the article]

Blackstone Inc. is making changes to the leadership of its team that buys stakes in other private equity firms. Mustafa Siddiqui, who previously led the business, has decided to leave. The team will now be under the secondaries arm, led by Verdun Perry, which buys and builds portfolios of fund assets. This move is an attempt to reinvigorate the group, which has faced increased competition for deals and talent. Blackstone is continuing to search for deals for its latest stakes fund and plans to move forward with a new fund. [Extracted from the article]

The article focuses on the tax treatment of a publicly traded partnership (PTP) in the U.S. It mentions investments in PTPs can cause investors to be required to file additional foreign reporting forms, they can also require multiple state income tax filings. It also mentions PTPs an investor's deduction of losses may be limited by the basis, at-risk, and passive-activity-loss rules, and gifts of interests to charities are subject to the bargain-sale rules.

Energy Transfer LP and Sunoco LP have formed a joint venture in the Permian Basin, combining their crude oil and produced water gathering assets. Energy Transfer will be the operator of the joint venture and contribute its assets and operations, while Sunoco will contribute its crude oil gathering assets. The joint venture will operate over 5,000 miles of pipelines and have a storage capacity of over 11 million barrels. Energy Transfer will hold a 67.5% interest in the joint venture, while Sunoco will hold a 32.5% interest. The joint venture is expected to be immediately beneficial to both companies. Energy Transfer LP owns and operates a large portfolio of energy assets in the US, while Sunoco LP is an energy infrastructure and fuel distribution master limited partnership operating in multiple countries. [Extracted from the article]

In a recent opinion, Bandera Master Fund LP v. Boardwalk Pipeline Partners LP, the Delaware Court of Chancery considered whether a general partner of a master limited partnership (the "Partnership") breached the Partnership's limited partnership agreement by exercising a contractual call right when the conditions precedent to such exercise were not satisfied. In Bandera, the Partnership's general partner possessed a call right entitling the general partner to purchase the Partnership's limited partnerships units that the General Partner and its affiliates did not own if certain conditions precedent were satisfied. [Extracted from the article]

The article focuses on losses that are beneficial for tax purposes and mentions losses from entities affected qualified business income (QBI) deduction. Topics discussed include unadjusted basis immediately after acquisition (UBIA) of proper amounts, zero QBI deduction due to net qualified business loss and losses from publicly traded partnership (PTP) income.

The article offers business news briefs. Dead River Company announces Casey Cramton as the new president and chief executive officer effective from July 1, 2022. Suburban Propane Partners, a nationwide distributor of propane, renewable propane, fuel oil and related products partnered with Veterans Bridge Home (VBH), a Charlotte-based nonprofit organization. Jeffrey Hale Suntup has issued a third patent by in May for its "Method for training heating oil tank truck drivers."

The article presents investment recommendations from the investor Ryan Crane and discusses the investment strategies of the investors Chuck Tharnstrom and David Tracy, who frequently manage the assets of celebrity movie stars, musicians, and entrepreneurs. According to the article, Tharnstrom and Tracy use a "hybrid bucket" allocation strategy that balances equities, fixed-income securities, foreign bonds, and hedge funds. Tracy's reputation among celebrities is emphasized. Senior bank debt and master limited partnerships are mentioned.

The article discusses the career and assets of Richard Kinder, the chief executive officer of the U.S. energy firm Kinder Morgan Energy Partners, focusing on investments and capacity expansions in pipelines for the transportation of oil and natural gas. Topics include the production of oil and shale drilling in the U.S. as of December, 2012, political obstacles to the construction of pipelines, the temporary renaming of the interests management company Kinder Morgan Inc. as Knight Inc., and master limited partnerships. Kinder's former role at the energy company Enron Corp. is mentioned. Other pipeline entrepreneurs including Kelcy Warren, Dan Duncan, and Charles Koch are mentioned.