SubChapter K Tax: Qualifying Income of a Publicly Traded Partnership under IRC 7704 - IRS Private Letter Ruling 201027003

SubChapter K Tax: Qualifying Income of a Publicly Traded Partnership under IRC 7704 - IRS Private Letter Ruling 201027003: "This letter responds to a letter from your authorized representative dated February 16, 2010 submitted on behalf of X requesting a ruling under the publicly traded partnership rules of �7704 of the Internal Revenue Code.

X was organized as a limited partnership under the laws of State. It is a publicly traded partnership within the meaning of � 7704(b). X is engaged through its operating partnership, Y, and through Y's subsidiaries (hereinafter, any references to X include a reference to Y and Y's subsidiaries), in a variety of activities, including the marine transportation of crude oil, refined petroleum products and other products for a variety of charterers, including major and independent oil and gas refining companies and petroleum marketing companies. X currently provides its marine transportation services under (i) spot contracts covering a single voyage and (ii) term contracts that range from a to b in length. Vessel charters, including fully found charters, time charters, consecutive voyage charters, contracts of affreightment and single voyage charters, as currently in effect and as may be entered into in the future, are referred to herein as the “Charters”."