Description of Additional Tax Proposals Submitted By Members for Ways And Means Committee Revenue Reconciliation Consideration Jcx-13-87

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— Publicly traded limited partnerships that engage in active business activities would be treated as corporations for Federal income tax purposes.
Publicly traded partnerships would include those whose interests are traded on existing exchanges (including over the counter) and those in which a market is effectively made.
Treatment under the passive loss rule . — Publicly traded limited partnerships that do not engage in active business activities would be treated as entities that do not pass th
...rough tax losses or deductions to limited partners, and limited partners' net income from the partnership would be treated as portfolio income to the partners under the passive loss rule.
Unrelated business income . --Tax-exempt organizations' distributive shares of income from any publicly traded limited partnership (that is not treated as a corporation for Federal income tax purposes) would be treated as unrelated business taxable income without regard to the underlying character of the income.


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