Thomas Humphreys and Remmelt Reigersman, Morrison & Foerster; Tom Young, IFLR
Traditionally, most public companies in the US were organised as C-corporations. However, tax developments in recent years have given corporate planners a wide range of new tools to structure a public company. For example, tax pass-through MLP and Reit structures are spreading into new asset classes. Also, traditional double taxed ‘C’ corporations are using tax pass-through entities, including partnerships, to reduce or eliminate entity-level taxes as well as optimise their internal structures with tax ‘disregarded entities’. These new tools lead to a variety of tax choices in deciding how to structure a public company.
During this briefing, which is intended for a general audience, the speakers will explain the structures, restrictions and pitfalls in this evolving hybrid world of C-corporations mixed with tax pass-throughs. Specifically, they will discuss:
•Master limited partnerships;
•Reits and alternative assets that may qualify as ‘real estate’;
•Business development companies;
•Consolidated groups of corporations and disregarded entities; and
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