Impacts of the Tax Reform Legislation on UP-C Structures
With the recent enactment of H.R. 1, formerly known by the short title Tax Cuts and Jobs Act (the “TCJA”), it is a good time to review how this tax reform legislation could affect the desirability of umbrella partnership–C-corporation (UP-C) structures in initial public offerings. Our conclusion is that the UP-C structure continues to provide meaningful tax benefits to pre-IPO owners of a pass-through business.