Joshua Ford Bonnie and William Golden Co-Author Practice Note on UP-C IPO Structures with Practical Law
Simpson Thacher Corporate Partners Josh Bonnie and William Golden co-authored a Practice Note with Practical Law Corporate & Securities that provides an overview of the Umbrella Partnership – C-corporation (UP-C) IPO structure and selected related legal and tax considerations. The article discusses that by implementing an UP-C structure instead of more traditional IPO structures, pre-IPO owners of businesses taxed as partnerships can receive substantial post-IPO tax benefits even following recent tax reforms.