Impacts of the Tax Reform Framework on UP-C Structures
With the recent release of a tax reform framework by President Trump and Republican Congressional leaders (the “Tax Reform Framework”), it is a good time to review how tax reform could affect the desirability of umbrella partnership – C-corporation (UP-C) structures. Our conclusion is that, even if the Tax Reform Framework is enacted, UP-C structures are likely to continue to provide tax and other benefits to pre-IPO owners of a pass-through business in a manner similar to current law.