A publicly traded partnership (PTP) is treated as a corporation for federal tax purposes unless 90 percent or more of its gross income consists of qualifying income. A partnership is publicly traded if interests in the partnership are traded on an established securities market or interests in the partnership are readily tradable on a secondary market for the substantial equivalent thereof. Qualifying income includes passive-type income such as interest, dividends, real property rents, and gain from the deposition of real property as well as income and gains from certain natural resource activities. In Ltr. Rul. 200827022, a PTP's expected income from drilling and completion services was determined to be qualifying income. In Ltr. Rul. 200827014, a PTP's expected income from fees paid for removing and disposing of, or recycling, fluids generated by oil and gas production, at oil and gas wells that do not utilize fracturing, was determined to be qualified income.
PUBLICLY TRADED PAR
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"PUBLICLY TRADED PARTNERSHIP QUALIFYING INCOME FROM NATURAL RESOURCES: TEXTUALISM1 TAKES A HOLIDAY"Please download to view full document