Master Limited Partnership
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Master Limited Partnership
In the United States, a master limited partnership (MLP) or publicly traded partnership (PTP) is a publicly traded entity taxed as a partnership. It combines the tax benefits of a partnership with the liquidity of publicly traded securities. To obtain the tax benefits of a pass through, MLPs must generate at least 90% or more of their income from qualifying sources such as from production, processing, storage, and transportation of depletable natural resources and minerals. In addition, real property rents also qualify. While the "MLP" and "PTP" terms are commonly used interchangeably, MLPs are technically a type of limited partnership that conducts its operations through subsidiaries, and are not always publicly traded. While most PTPs are organized as MLPs, a PTP may be organized as a limited liability company that elects to be taxed as a partnership. History In 1981, Apache Corporation formed the United States' first MLP, Apache Petroleum Company (APC). Apache’s success d ...
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United States
The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 states, a federal district, five major unincorporated territories, nine Minor Outlying Islands, and 326 Indian reservations. The United States is also in free association with three Pacific Island sovereign states: the Federated States of Micronesia, the Marshall Islands, and the Republic of Palau. It is the world's third-largest country by both land and total area. It shares land borders with Canada to its north and with Mexico to its south and has maritime borders with the Bahamas, Cuba, Russia, and other nations. With a population of over 333 million, it is the most populous country in the Americas and the third most populous in the world. The national capital of the United States is Washington, D.C. and its most populous city and principal financial center is New York City. Paleo-Americ ...
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Real Estate
Real estate is property consisting of land and the buildings on it, along with its natural resources such as crops, minerals or water; immovable property of this nature; an interest vested in this (also) an item of real property, (more generally) buildings or housing in general."Real estate": Oxford English Dictionary online: Retrieved September 18, 2011 In terms of law, ''real'' is in relation to land property and is different from personal property while ''estate'' means the "interest" a person has in that land property. Real estate is different from personal property, which is not permanently attached to the land, such as vehicles, boats, jewelry, furniture, tools and the rolling stock of a farm. In the United States, the transfer, owning, or acquisition of real estate can be through business corporations, individuals, nonprofit corporations, fiduciaries, or any legal entity as seen within the law of each U.S. state. History of real estate The natural right of a person t ...
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Funds
Funding is the act of providing resources to finance a need, program, or project. While this is usually in the form of money, it can also take the form of effort or time from an organization or company. Generally, this word is used when a firm uses its internal reserves to satisfy its necessity for cash, while the term financing is used when the firm acquires capital from external sources. Sources of funding include credit, venture capital, donations, grants, savings, subsidies, and taxes. Fundings such as donations, subsidies, and grants that have no direct requirement for return of investment are described as "soft funding" or "crowdfunding". Funding that facilitates the exchange of equity ownership in a company for capital investment via an online funding portal per the Jumpstart Our Business Startups Act (alternately, the "JOBS Act of 2012") (U.S.) is known as equity crowdfunding. Funds can be allocated for either short-term or long-term purposes. Economics In economics fun ...
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Limited Partners
A limited partnership (LP) is a form of partnership similar to a general partnership except that while a general partnership must have at least two general partners (GPs), a limited partnership must have at least one GP and at least one limited partner. Limited partnerships are distinct from limited liability partnerships, in which all partners have limited liability. The GPs are, in all major respects, in the same legal position as partners in a conventional firm: they have management control, share the right to use partnership property, share the profits of the firm in predefined proportions, and have joint and several liability for the debts of the partnership. As in a general partnership, the GPs have actual authority, as agents of the firm, to bind the partnership in contracts with third parties that are in the ordinary course of the partnership's business. As with a general partnership, "an act of a general partner which is not apparently for carrying on in the ordinary c ...
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General Partner
General partner is a person who joins with at least one other person to form a business. A general partner has responsibility for the actions of the business, can legally bind the business and is personally liable for all the partnership's debts and obligations. Role of a general partner A general partner acts on behalf of a business, and generally has the power to make decisions with or without the permission of the other partners. Due to their managerial role general partners have unlimited liability, which means that a partnership's genera partners are personally responsible for all business debts, meaning that the personal assets of general partners are at potential risk for the debts of the partnership. In the event that a partnership is dissolved, general partners are subject to liquidation, such that their share of the assets of the partnership may be distributed to claimants such as creditors before the partner receives any remaining share. General partner v. limited p ...
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Ownership
Ownership is the state or fact of legal possession and control over property, which may be any asset, tangible or intangible. Ownership can involve multiple rights, collectively referred to as title, which may be separated and held by different parties. The process and mechanics of ownership are fairly complex: one can gain, transfer, and lose ownership of property in a number of ways. To acquire property one can purchase it with money, trade it for other property, win it in a bet, receive it as a gift, inherit it, find it, receive it as damages, earn it by doing work or performing services, make it, or homestead it. One can transfer or lose ownership of property by selling it for money, exchanging it for other property, giving it as a gift, misplacing it, or having it stripped from one's ownership through legal means such as eviction, foreclosure, seizure, or taking. Ownership is self-propagating in that the owner of any property will also own the economic benefits of that ...
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Partnership
A partnership is an arrangement where parties, known as business partners, agree to cooperate to advance their mutual interests. The partners in a partnership may be individuals, businesses, interest-based organizations, schools, governments or combinations. Organizations may partner to increase the likelihood of each achieving their mission and to amplify their reach. A partnership may result in issuing and holding equity or may be only governed by a contract. History Partnerships have a long history; they were already in use in medieval times in Europe and in the Middle East. According to a 2006 article, the first partnership was implemented in 1383 by Francesco di Marco Datini, a merchant of Prato and Florence. The Covoni company (1336-40) and the Del Buono-Bencivenni company (1336-40) have also been referred to as early partnerships, but they were not formal partnerships. In Europe, the partnerships contributed to the Commercial Revolution which started in the 13th centur ...
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Income
Income is the consumption and saving opportunity gained by an entity within a specified timeframe, which is generally expressed in monetary terms. Income is difficult to define conceptually and the definition may be different across fields. For example, a person's income in an economic sense may be different from their income as defined by law. An extremely important definition of income is Haig–Simons income, which defines income as ''Consumption + Change in net worth'' and is widely used in economics. For households and individuals in the United States, income is defined by tax law as a sum that includes any wage, salary, profit, interest payment, rent, or other form of earnings received in a calendar year.Case, K. & Fair, R. (2007). ''Principles of Economics''. Upper Saddle River, NJ: Pearson Education. p. 54. Discretionary income is often defined as gross income minus taxes and other deductions (e.g., mandatory pension contributions), and is widely used as a basis to co ...
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Private Letter Ruling
Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance. A letter ruling is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a specific set of facts." A letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated) but only those parties, so the ruling may not be relied on as precedent by other taxpayers. The IRS has the option, however, of redacting the personal content of a letter ruling and issuing that content as a revenue ruling, which may become binding on all taxpayers and the IRS.PLRs from 1997 onwards are availableto the public through the IRS Electronic reading room (see ). Similarity to technical advice memorandum A technical advice memorandum (TAM) is simi ...
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Basketball Team
Basketball is a team sport in which two teams, most commonly of five players each, opposing one another on a rectangular court, compete with the primary objective of shooting a basketball (approximately in diameter) through the defender's hoop (a basket in diameter mounted high to a backboard at each end of the court, while preventing the opposing team from shooting through their own hoop. A field goal is worth two points, unless made from behind the three-point line, when it is worth three. After a foul, timed play stops and the player fouled or designated to shoot a technical foul is given one, two or three one-point free throws. The team with the most points at the end of the game wins, but if regulation play expires with the score tied, an additional period of play (overtime) is mandated. Players advance the ball by bouncing it while walking or running (dribbling) or by passing it to a teammate, both of which require considerable skill. On offense, players may use a ...
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Boston Celtics
The Boston Celtics ( ) are an American professional basketball team based in Boston. The Celtics compete in the National Basketball Association (NBA) as a member of the league's Eastern Conference Atlantic Division. Founded in 1946 as one of the league's original eight teams, the Celtics play their home games at TD Garden, which they share with the National Hockey League's Boston Bruins. The Celtics are one of the most successful basketball teams in NBA history. The franchise is one of two teams with 17 NBA Championships, the other franchise being the Los Angeles Lakers. The Celtics currently hold the record for the most recorded wins of any NBA team. The Celtics have a notable rivalry with the Los Angeles Lakers, which was heavily highlighted throughout the 1960s and 1980s. During the two teams' many match-ups in the 1980s, the Celtics' star, Larry Bird, and the Lakers' star, Magic Johnson, had an ongoing feud. The franchise has played the Lakers a record 12 times in the NB ...
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