Moving away from the C-corporation: understanding Reits, MLPs, PTPs and BDCs

Presented by

Thomas Humphreys and Remmelt Reigersman, Morrison & Foerster; Tom Young, IFLR

About this talk

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 •Up-C structures. Nb: By signing up for IFLR webinars, you agree to receive follow-up communications from IFLR and the webinar sponsor but you can unsubscribe at any time

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