The IRS and Treasury issued proposed regulations that provide guidance as to whether activities with respect to minerals or natural resources will produce qualifying income for purposes of section 7704(d)(1)(E)  The proposed regulations provide that qualifying activities relating to minerals or natural resources include: (1) the exploration, development, mining or production, processing, refining, transportation, or marketing of minerals or natural resources, and (2) certain limited support activities that are “intrinsic” to section 7704(d)(1)(E) activities.