This is the premier publication on the taxation of Master Limited Partnerships (MLPs) and their partners. Master Limited Partnerships are sophisticated publicly traded entities that are sometimes referred to as "publicly traded partnerships." This publication provides in-depth coverage of all the key issues involving Master Limited Partnerships. Master Limited Partnerships are typically engaged in certain businesses, primarily oil and gas, real estate and financial services. They are highly attractive to investors as they tend to provide yields superior to bonds and corporate dividends. This publication discusses the significant tax advantages by virtue of the MLP's status as a pass-through entity. MLPs are highly complex entities with significant administrative burdens which are discussed in detail. Moreover, MLP investors face tax complexities by virtue of the pass-through nature of the entity, This publication also explores the fact that MLPs are not subject to corporate tax or fluctuations in the investors' basis as a result of cash distributions. This treatise provides a detailed discussion of the tax issues associated with the entire life cycle of an MLP, from its formation to its operation and ultimate liquidation. This treatise simplifies these complex rules and provides the reader with a practical understanding thereof. It includes real-life examples illustrating the application of the relevant tax rules to commonly-encountered MLP fact patterns. References are made throughout the treatise to specific MLP structures that currently exist in the marketplace so as to provide focus and practical application of the rules.

As of June 2013, Master Limited Partnerships ("MLPs") have reached a market capital of $400 billion, with over 100 MLPs traded on major exchanges. Generally established as LLCs with advantageous partnership flow through tax treatment, MLPs present attractive return vehicles to attract long term capital to the energy extraction, energy transportation ("midstream"), and most recent, energy distribution ("downstream"), markets. However, MLPs may result in unfavorable tax treatment for investors as well.This Highlight will present the tax issues for MLP investors pre- and post- the 1985 Code, imposed MLP investment restrictions, and gradual relaxation thereof. The Highlight will conclude with an analysis of the April 2013 legislative bi-partisan proposal, the Master Limited Partnership Parity Act, to extend MLP tax treatment to renewable ("green") energy, and why this proposal is contentious.