Glenn E. Dance, Partner at Ernst & Young, LLP

This is the premier publication on the taxation of Master Limited Partnerships (MLPs) and their partners. Master Limited Partnerships are sophisticated publicly traded entities that are sometimes referred to as "publicly traded partnerships."

This treatise provides a detailed discussion of the tax issues associated with the entire life cycle of an MLP, from its formation to its operation and ultimate liquidation. This treatise simplifies these complex rules and provides the reader with a practical understanding thereof. It includes real-life examples illustrating the application of the relevant tax rules to commonly-encountered MLP fact patterns. References are made throughout the treatise to specific MLP structures that currently exist in the marketplace so as to provide focus and practical application of the rules.

1. An Introduction to Master Limited Partnerships
2. Comparison of MLPs to Other Types of Business Organizations
3. Application of MLP Qualified Income Test
4. Tax Issues Associated with the Marketability of MLP Interests
5. Tax Issues Associated with the Formation of an MLP
6. Classes of MLP Interests and the Allocation of Taxable Income
7. Tax Allocation Issues Related to Built-In Gain or Loss Property
8. Basis Adjustments Resulting from Transfer of MLP Interest
9. Tax Treatment of Disposition of MLP Units
10. Tax Reporting Issues for MLPs

7" x 10"     500 pages

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Author: Glenn E. Dance, Partner at Ernst & Young, LLP

This is the premier publication on the taxation of Master Limited Partnerships (MLPs) and their partners. It discusses the significant tax advantages by virtue of the MLP's status as a pass-through entity. MLPs are highly complex entities with significant administrative burdens which are discussed in detail. Moreover, MLP investors face tax complexities by virtue of the pass-through nature of the entity, This publication also explores the fact that MLPs are not subject to corporate tax or fluctuations in the investors' basis as a result of cash distributions.

This treatise provides a detailed discussion of the tax issues associated with the entire life cycle of an MLP, from its formation to its operation and ultimate liquidation. It simplifies these complex rules and provides the reader with a practical understanding thereof. It includes real-life examples illustrating the application of the relevant tax rules to commonly-encountered MLP fact patterns.

1. An Introduction to Master Limited Partnerships
2. Comparison of MLPs to Other Types of Business Organizations
3. Application of MLP Qualified Income Test
4. Tax Issues Associated with the Marketability of MLP Interests
5. Tax Issues Associated with the Formation of an MLP
6. Classes of MLP Interests and the Allocation of Taxable Income
7. Tax Allocation Issues Related to Built-In Gain or Loss Property
8. Basis Adjustments Resulting from Transfer of MLP Interest
9. Tax Treatment of Disposition of MLP Units
10. Tax Reporting Issues for MLPs

500 pages

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The increase in European Community memberships and the steady evolution of the harmonization process means that international business opportunities are also on the rise. This convenient resource provides quick and easy guidance on a variety of corporate and partnership considerations that arise in international business, such as mergers, rights and duties of interested parties, stock exchange directives, labor laws and takeovers.

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