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Summary Unrelated Business Taxable Income (UBTI) is the income that can trigger Unrelated Business Income Tax (UBIT) for tax-exempt organizations and retirement accounts. Investors can own MLPs ...
In 1981, Apache Corporation formed the United States' first MLP, Apache Petroleum Company (APC). Apache’s success drew other oil and gas companies to the MLP structure. Real estate companies soon followed, and by the mid-1980s, MLPs became so popular that they were adopted in a variety of industries, such as restaurants, hotels and cable TV.
To address these issues, a private equity fund can set up a U.S. feeder corporation known as a blocker corporation. The foreign and tax exempt investors can invest through the blocker corporation, and then they are no longer personally considered to be partners, as it is the domestic corporation that is the owner of equity in the fund.
Unrelated Business Income Tax (UBIT) in the U.S. Internal Revenue Code is the tax on unrelated business income, which comes from an activity engaged in by a tax-exempt 26 U.S.C. 501 organization that is not related to the tax-exempt purpose of that organization.
Summary There are two types of MLP funds – those structured as RICs, which own up to 25% MLPs, and those structured as corporations, which tend to be 90-100% MLPs. Similar to direct MLP ...
In preparation for tax season, many investors are trying to find the best stocks to buy with the cash they inject into their retirement accounts before the April 15 deadline. Given the growing ...
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The downside of a strategy of retaining profits offshore is that corporations may want or need to pay dividends to shareholders, or to make investments in the United States, besides other reasons. The alternative may be to borrow funds in the U.S., [3] or access the funds retained offshore in the form of inter-company loans.