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Friday, June 15, 2007


So even though my scholarship thus far tends in a different direction, I will admit to being a total deal junkie. Yes, surprise, the tax lawyer in me gets a kick out of contemplating the little boxes and arrows that make up complicated transactional structures. The Blackstone Group IPO is great food for that habit, with a lovely structure that takes advantage of the statutory provision that allows publicly traded partnerships with 90% passive income to enjoy pass-through treatment and avoid the double taxation hit inherent in the corporate income tax. Now Congress is stepping in with the probably inevitable legislative fix to keep the financial services sector from reorganizing itself along similar lines, with a built-in transition that allows Blackstone to enjoy the benefits of its structure for five years.  The Blackstone structure raises a thousand interesting questions -- too many to cover in a single blog post.  Vic Fleischer has a great series of lengthy posts on the deal that you can access here. Paul Caron collects reactions to the proposed legislation here.

Hat tips:  Conglomerate and TaxProf Blog

Posted by Kristin Hickman on June 15, 2007 at 02:23 PM | Permalink


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