The regulations do not define what would be deemed to be a substantial ownership interest by the limited partners
but Revenue Procedure 89-12 provides a safe harbor amount.
In reviewing the prospectus, it makes sense to talk to limited partners
from prior projects.
Within the past 10 years, several cases were decided rejecting the IRS position that members of LLCs were limited partners
for purposes of Sec.
1402(a)(13) provides that earnings from partnerships that are attributed to a limited partner
, as such, are excluded from the definition of net earnings from self-employment unless the earnings are Sec.
The proposed regulation set forth guidelines to determine whether an individual who owns a partnership interest should be treated as a limited partner
rather than a general partner by defining when an individual who owns an interest in a partnership would be treated as a limited partner
for federal tax purposes.
The company's limited partner
cloud is designed for large institutional investors, endowments, family offices, fund of fund managers, high net-worth individuals, consultants and advisors.
1402(a)(13) generally excludes limited partners
of limited partnerships from self-employment tax; however, a limited partner
does pay self-employment tax on guaranteed payments received from the partnership for services.
Delek Logistics Partners LP (NYSE:DKL) announced on Saturday that it will pay a quarterly cash distribution of USD0.61 per limited partner
unit for the first quarter 2016.
Rattler Midstream LP (RTLR), a subsidiary of Diamondback Energy (FANG), and Diamondback announced the launch of Rattler's initial public offering of 33.33M common units representing limited partner
interests at an anticipated initial offering price between $16.00 and $19.00 per common unit.
(NASDAQ: ARLP) has closed the acquisition of the general partner interests in Texas, US-based mining group AllDale Minerals, LP and AllDale Minerals II, LP and all limited partner
interests in AllDale not currently owned by ARLP's affiliate, North Carolina, US-based coal mining group Cavalier Minerals JV, LLC, the company said.