OAR 150-314-0480
Publicly Traded Partnerships Taxed as Corporations
# (1)
(1) "Publicly traded partnership" means a partnership with interests traded on an established securities market or readily tradable on a secondary market (or its substantial equivalent), including master limited partnerships, under the provisions of IRC 7704. Oregon adopted the provisions of IRC 7704 retroactively.
# (2)
(2) Publicly traded partnerships deriving less than 90 percent of their gross income from qualifying passive-type income sources are treated as corporations for federal and Oregon tax purposes. Examples of qualifying income sources include interest, dividends, real property rents, gain from the disposition of real property, mining and natural resource income, and gain from the disposition of capital assets or IRC 1231(b) property held for the production of such income.
# (3)
(3) A publicly traded partnership that was not an existing partnership on December 17, 1987, shall be treated as a corporation for tax years beginning after December 31, 1987.
# (4)
(4) A publicly traded partnership that was an existing partnership on December 17, 1987, shall be treated as a corporation for tax years beginning after December 31, 1997.
Amendment history
Renumbered from 150-314.722, REV 34-2016, f. 8-12-16, cert. ef. 9-1-16
Source: view the official text
In this chapter (40 sections)
- 150-314-0385 · Apportionment Formula
- 150-314-0390 · Property Factor; In General
- 150-314-0392 · Property Factor; Property Used for the Production of…
- 150-314-0394 · Property Factor; Consistency in Reporting
- 150-314-0396 · Property Factor; Numerator
- 150-314-0398 · Property Factor; Valuation of Owned Property
- 150-314-0400 · Property Factor; Valuation of Rented Property
- 150-314-0402 · Property Factor; Timber
- 150-314-0404 · Property Factor; Intangible Drilling Costs
- 150-314-0406 · Property Factor; Averaging Property Value
- 150-314-0415 · Payroll Factor; In General
- 150-314-0417 · Payroll Factor; Numerator
- 150-314-0425 · Sales Factor; Definition of Gross Receipts
- 150-314-0427 · Sales Factor; Numerator
- 150-314-0429 · Sales Factor; Sales of Tangible Personal Property in…
- 150-314-0431 · Sales Factor; Sales of Tangible Personal Property to…
- 150-314-0435 · Sales Factor; Sales Other Than Sales of Tangible…
- 150-314-0437 · Gross Receipts Related to Deferred Gain or Loss
- 150-314-0455 · Modified Factors for Publishing
- 150-314-0460 · Apportionment of Net Loss
- 150-314-0465 · Sales Factor for Interstate Broadcasters
- 150-314-0466 · Definition of Programming and Subscription Services
- 150-314-0470 · Interstate Broadcasters: Net Income Attributable to this…
- 150-314-0475 · Consistent Treatment of Partnership Items
- 150-314-0480 · Publicly Traded Partnerships Taxed as Corporations
- 150-314-0485 · Partnership Information Returns
- 150-314-0487 · Partnership Penalty
- 150-314-0495 · Corporation Tax Credits — Converting a C Corporation to…
- 150-314-0497 · Corporation Tax Credits — Converting an S Corporation to…
- 150-314-0510 · Definitions for Composite Tax Returns and Pass-through…
- 150-314-0515 · Oregon Composite Tax Return
- 150-314-0520 · Pass-through Entity Withholding Requirements
- 150-314-0521 · Pass-through entity elective tax: Estimated tax;…
- 150-314-0522 · Pass-through entity elective tax: Electing entities…
- 150-314-0525 · Exceptions to Pass-through Entity Withholding…
- 150-314-0530 · Divulging Particulars of Returns and Reports Prohibited
- 150-314-0535 · Information That May Be Furnished
- 150-314-0540 · Rewards for Information
- 150-314-0545 · Combat Zone Benefits
- 150-314-0733 · Partnership Pays Election After Federal Centralized…