3.26 Ark. Code R. § 102(4) - Publicly Traded Partnership (PTP)

A publicly traded partnership (PTP) is taxable as a corporation. IRC Sec. 7704(a). A partnership is a publicly traded partnership if interests in the partnership either:

(1) are traded on an established securities market, or

(2) are readily tradable on a secondary market or its substantial equivalent. IRC Sec. 7704(b). However, a publicly traded partnership won't be treated as a corporation if, for each tax year beginning after 1987, at least 90% of its gross income is specified passive-type income, and certain other requirements are met. IRC Sec. 7704(c). Certain existing partnerships that were publicly traded partnerships on December 17, 1987, won't be treated as corporations until tax years beginning after 1997.

Notes

3.26 Ark. Code R. § 102(4)