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.

Publicly-traded energy master limited partnerships (MLPs) are a specialized investment class that possess favorable investment characteristics. They currently provide high yields coupled with the potential for growing these yields in the future. MLPs are less volatile than stocks and are therefore arguably less risky. They also possess favorable tax advantages. They are not taxed at the entity level and a significant portion of the income generated by the MLP may be tax-deferred. MLPs are normally best suited for a taxable account since tax-exempt entities such a IRAs are taxed on MLP income above a modest amount.Because, however, MLPs are subject to the laws governing partnership taxation, the tax issues surrounding MLPs are considerably more involved than the tax issues surrounding stocks. This article provides an overview of this unique asset class, including their tax history. Also, the tax issues surrounding MLPs such as determining adjusted basis, compliance with the passive activity rules, determining how much of sales proceeds to allocate between Section 741 and 751, and reporting tax shelter registration numbers are addressed. Fortunately, the MLP itself will aid the investor by computing the adjusted basis as well as the Section 741 gain or loss and Section 751 gain for the investor.