A publicly traded partnership
taxed as a corporation under the above rules is treated, in general, as a taxable entity and tax benefits are taken at the partnership level.
With the exception of certain publicly traded partnerships
, a partnership, as such, is not taxed.
Combined QBI is defined in IRC section 199A(b) as an amount equal to the sum of the QBI amounts for each QBI plus 20% of the aggregate amount of qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership
income of the taxpayer for the taxable year.
On 5 May 2015, Crestwood Equity and Crestwood Midstream announced they had entered into a definitive agreement to merge the two publicly traded partnerships
and simplify Crestwood's corporate structure into a single publicly traded partnership
However, when a publicly traded partnership
is taxed as a corporation, investors are unable to take partnership deductions, credits, and income on their own tax returns.
QR Energy LP (NYSE: QRE), a publicly traded partnership
engaged in the acquisition, production and development of onshore crude oil and natural gas properties in the United States, has signed a contract to acquire oil properties located in the Ark-La-Tex area and Michigan, from an undisclosed private seller.
(Electing large partnerships have somewhat different flow-through rules than regular partnerships (see Q 7784).) However, if a publicly traded partnership
is taxed as a corporation, the income, deductions, and credits are reported by the partnership and do not flow through to the partners.
The publicly traded partnership
managing a diversified portfolio of energy assets said it intends to sell 5m common units in a registered public offering that will be co-managed by RBC Capital Markets and UBS Investment Bank.
The IRS plans to issue guidance regarding technical terminations of a publicly traded partnership
(PTP) resulting in multiple short tax years within one calendar year, which can cause considerable problems for taxpayers.
Magellan Midstream Partners is a publicly traded partnership
formed to own, operate and acquire a diversified portfolio of energy assets.
Observation: If the IRA had invested in a publicly traded partnership
instead of a nonpublicly traded partnership the results would have been the same.