Delek Logistics Partners LP priced its initial public offering (IPO) of 8,000,000 common units, representing limited partner
interests in Delek Logistics, at USD21.
These cases concluded that a member of an LLC or an LLP who can exercise management authority is not automatically treated as a limited partner
for purposes of applying the Sec.
When a limited partner
who has guaranteed a debt wants to leave the partnership, he must satisfy the guarantee or have it cancelled.
For a gifted FLP limited partner
interest to qualify for the annual gift tax exclusion under Subsection 2503(b)--$11,000 per donee, per year--the limited partner
interest must be a present interest.
A limited partner
cannot do either of these things.
Through an FLP, substantial value can be transferred through assignments of interests as a limited partner
at a time when the client's legal seas are calm, with control over and possession of partnership assets retained by the client through his or her interest as a general partner.
The Schedule K-1s were distributed to each limited partner
and the limited partners
used the numbers on it as deductions in filling out their individual returns.
4875 per limited partner
unit(C)2011 M2 COMMUNICATIONS http://www.
In a recent case the court held that a substantial payment a limited partner
made when abandoning a partnership interest was taxable income rather than a capital contribution.
Under the Uniform Limited Partnership Act, a creditor of a limited partner
is only entitled to attach the limited partner
's interest in the partnership.
The first question the court considered was whether to treat the taxpayer as a limited partner
or a general partner.
4625 per limited partner
unit(C)2010 M2 COMMUNICATIONS http://www.