Tax Treatment of Master Limited Partnerships: Scheduled for Hearings Before the Subcommittee on Select Revenue Measures of the Committee on Ways and Means on June 30 and July 1, 1987U.S. Government Printing Office, 1987 - 41 pages |
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Common terms and phrases
American Law Institute amount apply argue assets attributable to nonrecourse business activities capital gains conduit treatment contributed property cooperative corporate debt corporate sponsor corporate tax base deduction dividends elect entity classification exchange extent Federal income tax financing gain or loss grantor Grantor trusts holders investors levels of tax limited partner's basis limited partnership units master limited partner master limited partnerships MLPs nerships nomic nonrecourse debt nonrecourse liabilities ordinary income partnership income partnership interest partnership liabilities partnership losses partnership sec partnerships as corporations passive loss rule passthrough entities percent permitted poration present law primary offering publicly traded limited rate tax real estate REIT REMIC requirements retained earnings rollout share of partnership shareholder's basis shifting allocations ship Subchapter subject to tax tax benefits tax treatment tax-exempt taxable income tion traded limited partnerships Treas Treasury regulations treated treatment of master types of entities Uniform Partnership Act unrelated business income
Popular passages
Page 12 - 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 9 - 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 24 - ... (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 9 - 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 28 - In testimony before the Subcommittee on Select Revenue Measures of the House Ways and Means Committee on June 9, 1986, the Treasury Department recommended that publicly traded limited partnerships be subject to tax as corporations.
Page 17 - 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 12 - 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 28 - Prt. 99-47, 99th Cong., 1st Sess. (1985), "The Subchapter C Revision Act of 1985, A Final Report Prepared by the Staff'). Preservation of the averaging function of carryovers The primary purpose of the special limitations is the preservation of the integrity of the carryover provisions. The carryover provisions perform a needed averaging function by reducing the distortions caused by the annual accounting system. If...
Page 13 - 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...