Westlake Chemical Partners LP Submits Comments on Proposed IRS Regulations
Revocation of Previous Private Letter Ruling is Unfair to Unitholders
HOUSTON, July 28, 2015 /PRNewswire/ -- Westlake Chemical Partners LP (NYSE: WLKP) (the "Partnership") today submitted comments in response to the proposed regulations that were issued on May 5, 2015 by the Internal Revenue Service ("IRS") and the U.S. Department of Treasury concerning section 7704(d)(1)(E) of the Internal Revenue Code. The Partnership issued previous statements on the proposed regulations on May 5 and June 3, 2015.
In conjunction with filing its comments today, the Partnership issued the following statement:
"The proposed regulations effectively revoke a previously issued private letter ruling ("PLR") by the IRS, which served as the underlying basis for the decision to form WLKP as a master limited partnership ("MLP") in 2014. WLKP believes this reversal, even with a ten-year transition period, is unfair to our unitholders and sends an unfortunate message to investors and businesses that they cannot rely on IRS rulings. Additionally, this proposed ruling has already had a significant negative impact on the market value of both WLKP and Westlake Chemical Corporation."
In particular, the Partnership's comments address the following:
- Section 7704 and its legislative history support the conclusion that the IRS reached in its prior PLR – that the processing of natural gas liquids via steam cracking generates qualifying income for an MLP;
- the IRS' proposed regulations create inconsistent results that treat similarly situated taxpayers differently; and
- to revoke WLKP's MLP status, even after a ten-year transition period, would be unfair, and more importantly would demonstrate that taxpayers and investors cannot reasonably rely on IRS guidance when making long-term business structuring or investment decisions.
The Partnership has been actively engaged with IRS and Treasury officials and appreciates their willingness to discuss the impact of the proposed regulations on the Partnership and its investors. The Partnership will continue to encourage them to revise the proposed regulations to align with the IRS' previous PLR.
WLKP encourages interested parties to view submitted comments on the proposed regulations via our dedicated website, http://wlkpartners.irsproposedregulations.com.
Interested parties may contact the IRS by mailing submissions to: CC:PA:LPD:PR (REG-132634-14), room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.
Submissions may also be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-132634-14), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC, or sent electronically. To submit electronically, go to our dedicated website at http://wlkpartners.irsproposedregulations.com and click on the button, "Submit Comments to IRS". You may also go to our company websites at www.wlkpartners.com or www.westlake.com for more information and to submit your comments. All comments must be submitted in advance of the August 4, 2015 deadline.
All statements, other than statements of historical facts, included in this press release that address activities, events or developments that the Partnership expects, projects, believes or anticipates will or may occur in the future, including but not limited to the Partnership's plans to comment on the Proposed Regulations, and the effect the Proposed Regulations might have on the Partnership's ability to satisfy the "qualifying income" requirements of Section 7704 of the Code, are forward-looking statements. Forward-looking statements can be identified by the use of words such as "believes," "intends," "may," "should," "could," "anticipates," "expects," "will" or comparable terminology, or by discussions of strategies or trends. Although the Partnership believes that the expectations reflected in such forward-looking statements are reasonable, the Partnership cannot give any assurances that these expectations will prove to be correct.
Westlake Chemical Partners LP (WLKP)
Westlake Chemical Partners is a limited partnership formed by Westlake Chemical Corporation to operate, acquire and develop facilities for the processing of natural gas liquids as well as other qualifying activities. Headquartered in Houston, TX, the Partnership owns a 13.3% interest in Westlake Chemical OpCo LP. Westlake Chemical OpCo LP's assets include three facilities in Calvert City, Kentucky, and Lake Charles, Louisiana which process ethane and propane into ethylene, and an ethylene pipeline. For more information about Westlake Chemical Partners LP, please visit http://www.wlkpartners.com/.
SOURCE Westlake Chemical Partners LP
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