No other firm has such extensive experience with UP-C and UP-PTP “umbrella partnership” tax structures and the complex, associated tax receivable (TRA) arrangements.
Podcast:
The “UP-C” Structure
12.17.19
In this 10-minute podcast, Corporate Partner Josh Bonnie and Tax Partner Drew Purcell discuss the basics of the “UP-C” structure and the related tax receivable agreements (TRAs), and the impact of tax reform on the use of these structures in IPOs.
To access and print the slides accompanying the podcast, please read here.
IPOs or spin-offs employing umbrella partnership structures that we have advised on include, among others: