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As a consequence of their pass-through status, holding MLPs in tax-exempt accounts may generate Unrelated Business Income Tax (UBIT). [2] To encourage tax-exempt investors, some MLPs set up C corporation holding companies of limited partner which can issue common equity. [3]
Individual retirement accounts generally are subject to tax on income that is taxable to most U.S. tax-exempt entities under 26 U.S.C. §511. 26 U.S.C. §408 contains many of the rules governing the treatment of Individual retirement accounts. §408(e)(1) states: "Any individual retirement account is exempt from taxation under this subtitle ...
Typically, 70-100% of MLP distributions have been considered a tax-deferred return of capital, which means one does not pay taxes on that portion of the distribution until the investor sells his ...
When there are tax exempt investors in a fund, they are not subject to U.S. income tax, but are still required to declare and pay taxes on "Unrelated Business Taxable Income" or "UBTI". [2] For tax exempt investors, dividends , royalties , rents , capital gains and interest income are not considered UBTI, but any money earned from conduct ...
Investors have long been attracted to MLPs for their generous yield, but a recent survey of over 600 financial advisors shows that the tax advantages of MLPs — including the potential for tax ...
Investors have long been attracted to MLPs for their generous yields, but the tax advantages of MLPs are not well understood. MLPs serve as a highly tax-efficient way to own midstream energy ...
For example, U.S. tax law provides that trading in securities for the taxpayer's own account will not constitute a U.S. trade or business. [16] Thus foreign hedge funds formed as corporations do not generally pay corporate income tax. [17] Domestic tax-exempt entities face similar concerns when investing in funds structured as partnerships.
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