AHIP is a limited partnership
formed under the Limited Partnerships
Act (Ontario) to invest in hotel real estate properties mainly in the US and it conducts business primarily in the railway employee accommodation, transportation and contract-focused lodging sectors.
New laws governing general partnerships, limited partnerships
and limited liability companies took effect on Jan.
In addition, many state laws now allow individuals to materially participate in an entity's business and retain limited liability, including limited partners in some limited partnerships
. The Sec.
(2) Although the family limited partnership
is an innovative use of existing laws regarding limited partnerships
, it should always be established for legitimate business and non-tax estate planning purposes.
The issue for the Tax Court was whether the taxpayers' interests in the LLPs, LLCs and tenancies in common were interests in limited partnerships
as limited partners and therefore presumptively passive activities.
The court additionally found interests in tenancies in common that were held by the taxpayers were not interests in limited partnerships
and, therefore, they also were not subject to the Sec.
One tricky aspect of hedge funds is that they generally are structured as limited partnerships
, said Mungovan.
There are a variety of different forms of limited partnerships
. These include:
Despite continuing attacks by the Internal Revenue Service, family limited partnerships
("FLPs"), and their sister entities, family limited liability companies electing to be taxed as partnerships, continue to be popular estate planning tools for a host of tax and nontax estate planning purposes.
Billed as one of the most effective asset protection tools in a financial planner's arsenal, family limited partnerships
(FLPs) have been touted as a way to safeguard assets while cutting income and estate taxes.
American Life's investments are private limited partnerships
. Limited partnerships
are the most common structure for multiple parties investing in US real estate.