The proposed regulations provide that if an election is made to aggregate all rental real estate interests, and if any of those interests are limited partnership
interests, the taxpayer can demonstrate material participation with respect to the one large activity only by using one of the three material participation tests available to limited partners.
Comparison of the limited partnership
units' features to the features of securities included in published studies on marketability and minority discounts.
While many other estate planning techniques still remain available to reduce or eliminate these client concerns, it appears that the family limited partnership
may be the optimal estate planning vehicle to be used in these situations.
11, 1998--Investors who receive offers -- known as "mini-tenders" -- to purchase their limited partnership
or untraded REIT securities need to be aware that such offers are not registered with the Securities and Exchange Commission and therefore avoid the usual disclosure and other securities law requirements, the Investment Program Association (IPA) warned today.
Venture Partners has raised approximately $650 million in various limited partnerships
, including approximately $190 million in 1996, and is one of the largest and most active venture capital investment firms in the country.
Biskind added that, "The newly formed limited partnership
, DDRC Great Northern Limited Partnership
will have the opportunity to update the tenant mix and the center itself.
The Silver Energy Limited Partnership
contains approximately $505,000 cash and owns certain land in the Silverdale area of Saskatchewan and the Kaybob Limited Partnership
contains approximately $255,000 cash and the right to earn an interest on certain lands in the Kaybob area of Alberta.
Around 30,000 firms registered as Scottish limited partnerships
will be forced to reveal their owners identities under laws.
According to the Tax Court, making such an inquiry would improperly blur the distinction between the special rule for limited partnerships
and the general rules for material participation in a manner that was "at odds with the statutory framework and legislative intent.
tax law, limited partnerships
and LLCs are considered to be partnerships and can elect to be treated as corporations for tax purposes.
In the 1980's, fast-buck syndicators pushing fee-driven and ill-conceived tax shelters gave limited partnerships
a bad name in the public consciousness.
In this case, the innovation was the widespread adoption of the limited partnership