Transcription of Internal Revenue Service Memorandum
{{id}} {{{paragraph}}}
Example: bachelor of science
Internal Revenue Service Memorandum
Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201517006 Release Date: 4/24/2015CC:PSI:01 POSTU-122684-12 , :October 09, 2014to:Associate Area Counsel, (CC:LB&I:)(Large Business & International )from:Chief, Branch 1(Passthroughs & Special Industries)subject:Whether a publicly traded partnership s restructuring of Incentive Distribution Rights into common units was a taxable Memorandum responds to your request for assistance. This advice may not be used or cited as Date 1=------------------Date 2=----------------Parent=--------------- ----------------a=--b=-----------POSTU-1 22684-122c=-------------d=-----------e=- --------------ISSUEDid a taxable exchange result when the general partner of a publicly traded partnership restructured its interest in the partnership , including exchanging its Incentive Distribution Rights for newly issued publicly-traded common units?
POSTU-122684-12 4 partners becoming limited partners and two partners becoming both limited and general partners. Each partner's total percent interest in the partnership's profits, losses, and
Tags:
Information
Domain:
Source:
Link to this page:
Please notify us if you found a problem with this document:
Related search queries
Economic Partnership Agreement, Agreement in Principle, Economic Partnership Agreement between the, COMPREHENSIVE ECONOMIC PARTNERSHIP AGREEMENT, COMPREHENSIVE ECONOMIC PARTNERSHIP AGREEMENT BETWEEN THE, Agreement, Economic, Economic partnership, CETA text, Compact, Partnership between, PARTNERSHIP AGREEMENT, IRS Goes After Partnership Liquidation, Partnership, Partnership Agreements, Contracts, MOA’s