Master Limited Partnerships: Hearing Before the Subcommittee on Taxation and Debt Management of the Committee on Finance, United States Senate, One Hundredth Congress, First Session, July 21, 1987U.S. Government Printing Office, 1988 - 305 pages |
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after-tax allocations American Law Institute Andrews & Kurth assets basis cash flow classification Committee Congress corporate form corporate income corporate level corporate tax base deduction disincorporation distributions dividends double tax economic effect equity existing Freeport-McMoRan funds individual investors issue level tax leveraged buyout liability limited partner liquidation master limited partnerships Mentz million MLP form MLP income MLP units MLP's MLPs as corporations nonrecourse debt offering oil and gas operating ordinary income partnership form partnership interests partnership units pass-through entities passive income passive loss rules percent portfolio income proposal publicly traded limited publicly traded partnerships raise real estate investment regulations REIT REMIC rental real estate result retained earnings revenue loss roll-up Senator BAUCUS ServiceMaster share shareholders significant single taxed substantial tax purposes tax rate Tax Reform Act tax revenues tax system tax treatment tax-exempt taxable income taxing MLPs testimony transaction Treasury Department treated yield
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Page 13 - RULE. — The grantor shall be treated as the owner of any portion of a trust in which he has a reversionary interest in either the corpus or the income therefrom if, as of the inception of that portion of the trust...
Page 10 - An organization has continuity of life if the death, insanity, bankruptcy, retirement, resignation, or expulsion of any member will not cause a dissolution of the organization.
Page 25 - ... (b) Termination. (1) General rule. For purposes of subsection (a), a partnership shall be considered as terminated only if — (A) no part of any business, financial operation, or venture of the partnership continues to be carried on by any of its partners in a partnership, or (B) within a 12-month period there is a sale or exchange of 50 percent or more of the total interest in partnership capital and profits.
Page 10 - Also, if a corporation is a general partner, personal liability exists with respect to such general partner when the corporation has substantial assets (other than its interest in the partnership) which could be reached by a creditor of the limited partnership.
Page 13 - ... associates and an objective to carry on business and divide the gains therefrom.
Page 29 - Policy) before the Subcommittee on Select Revenue Measures of the House Ways and Means Committee, Table 9, June 20, 1979).
Page 18 - cooperative housing corporation" means a corporation — (A) having one and only one class of stock outstanding, (B) each of the stockholders of which is entitled, solely by reason of his ownership of stock in the corporation, to occupy for dwelling purposes a house, or an apartment in a building, owned or leased by such corporation.
Page 13 - trust" as used in the Internal Revenue Code refers to an arrangement created either by a will or by an inter vivos declaration whereby trustees take title to property for the purpose of protecting or conserving it for the beneficiaries under the ordinary rules applied in chancery or probate courts.
Page 20 - In applying the existing regulations, the four corporate characteristics are: (1) continuity of life, (2) centralization of management, (3) liability for corporate debts limited to corporate property, and (4) free transferability of interests (Treas.
Page 14 - However, if the liquidation is unreasonably prolonged or if the liquidation purpose becomes so obscured by business activities that the declared purpose of liquidation can be said to be lost or abandoned, the status of the organization will no longer be that of a liquidating trust. Bondholders...