publicly traded partnership
Defined in 2 places of the United States Code.
For purposes of this section, the term “publicly traded partnership” means any partnership if—
(1) interests in such partnership are traded on an established securities market, or
(2) interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
Source
- 2013–present26 U.S.C. § 7704Internal Revenue Code · Certain publicly traded partnerships treated as corporations · for purposes of this section
For purposes of this section, the term “publicly traded partnership” means any partnership if—
(1) interests in such partnership are traded on an established securities market, or
(2) interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
(1) In general
Subsection (a) shall not apply to any publicly traded partnership for any taxable year if such partnership met the gross income requirements of paragraph (2) for such taxable year and each preceding taxable year beginning after December 31, 1987, during which the partnership (or any predecessor) was in existence. For purposes of the preceding sentence, a partnership shall not be treated as being in existence during any period before the 1st taxable year in which such partnership (or a predecessor) was a publicly traded partnership.
(2) Gross income requirements
A partnership meets the gross income requirements of this paragraph for any taxable year if 90 percent or more of the gross income of such partnership for such taxable year consists of qualifying income.
(3) Exception not to apply to certain partnerships which could qualify as regulated investment companies
This subsection shall not apply to any partnership which would be described in section 851(a) if such partnership were a domestic corporation. To the extent provided in regulations, the preceding sentence shall not apply to any partnership a principal activity of which is the buying and selling of commodities (not described in section 1221(1)), or options, futures, or forwards with respect to commodities.
For purposes of this section—
(1) In general
Source
- 1994–199926 U.S.C. § 7704Internal Revenue Code · Certain publicly traded partnerships treated as corporations · for purposes of this section
For purposes of this section, the term "publicly traded partnership" means any partnership if—
(1) interests in such partnership are traded on an established securities market, or
(2) interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
(1) In general
Subsection (a) shall not apply to any publicly traded partnership for any taxable year if such partnership met the gross income requirements of paragraph (2) for such taxable year and each preceding taxable year beginning after December 31, 1987, during which the partnership (or any predecessor) was in existence. For purposes of the preceding sentence, a partnership shall not be treated as being in existence during any period before the 1st taxable year in which such partnership (or a predecessor) was a publicly traded partnership.
(2) Gross income requirements
A partnership meets the gross income requirements of this paragraph for any taxable year if 90 percent or more of the gross income of such partnership for such taxable year consists of qualifying income.
(3) Exception not to apply to certain partnerships which could qualify as regulated investment companies
This subsection shall not apply to any partnership which would be described in section 851(a) if such partnership were a domestic corporation. To the extent provided in regulations, the preceding sentence shall not apply to any partnership a principal activity of which is the buying and selling of commodities (not described in section 1221(a)(1)), or options, futures, or forwards with respect to commodities.
For purposes of this section—
(1) In general
Source
- 1999–202526 U.S.C. § 7704Internal Revenue Code · Certain publicly traded partnerships treated as corporations · for purposes of this section
For purposes of this section, the term “publicly traded partnership” means any partnership if—
(A) interests in such partnership are traded on an established securities market, or
(B) interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
Source
- 1994–present26 U.S.C. § 469Internal Revenue Code · Passive activity losses and credits limited · for purposes of this section