In CCA 201517006 (dated 10/9/14 and released 4/24/15), the general partner of a publicly traded partnership (PTP) had, in addition to its capital interest, a profits interest in the PTP called “incentive distribution rights”...more
More details of the American Taxpayer Relief Act of 2012, which President Obama signed into law yesterday, January 2, 2013, will be release shortly. But in the meantime, we know from the text of the legislation (HR 8) that...more