Publicly Traded Partnerships (PTPs): Structure, Tax Benefits, and Real-Life Examples


Publicly traded partnerships (PTPs) are unique business structures that offer the benefits of limited partnerships and the liquidity of publicly traded securities. ptps are defined by their ability to trade on established securities markets and generate income primarily from qualifying sources. this article explores the concept of ptps, their tax advantages, differences from master limited partnerships (MLPs), and the implications for investors. dive into this comprehensive guide to gain a deeper understanding of publicly traded partnerships and their role in the world of finance.

Understanding publicly traded partnerships

a publicly traded partnership (PTP) is a business organization characterized by multiple co-owners, and their ownership shares are actively traded on established securities markets. ptps often share similarities with master limited partnerships (MLPs), but they have distinctive features that set them apart.

Ownership structure

a PTP is structured as a limited partnership, managed by two or more general partners, which can be individuals, corporations, or other partnerships. these general partners have a direct role in managing the business. on the other hand, limited partners provide capital to the partnership but do not participate in its day-to-day operations.

Qualifying income

ptps must meet specific criteria outlined in the U.S. code. one of the key requirements is that 90% of a PTP’s income must come from “qualifying” sources. these sources are stipulated in the internal revenue code and encompass various revenue streams, including interest, dividends, real property rents, and gains from the sale of real property.

qualified income extends to activities related to the exploration, development, mining, production, transportation, and marketing of natural resources, such as petroleum, natural gas, geothermal energy, and timber. it also covers income from the transportation or storage of fuels, the sale of capital assets, and certain commodities and commodity derivatives.

Tax benefits

one of the most significant advantages of ptps is their favorable tax treatment. these partnerships avoid the statutory corporate income tax at both state and federal levels. this tax-efficient structure enables them to pass more income to investors compared to corporations.

Taxation of distributions

ptps distribute income to their partners in the form of quarterly cash distributions. while these payments may resemble corporate dividends, they are taxed differently and more favorably. investors benefit from these distributions as they are considered a return of capital rather than ordinary income. this tax treatment reduces the partner’s basis with each distribution and allows for the utilization of depreciation and tax losses.

Publicly traded partnerships vs. MLPs

the terms “master limited partnership” (MLP) and “publicly traded partnership” are often used interchangeably, but there are subtle distinctions between the two.

Ownership and structure

mlps typically represent a tiered limited partnership structure where partners may have different roles and levels of commitment. one partner might manage the partnership, while another contributes capital. in contrast, ptps are publicly traded limited partnerships with a more straightforward structure.

LLCs as PTPs

it’s worth noting that not all ptps are mlps. some ptps are publicly traded limited liability companies (llc) that have chosen to be taxed as partnerships. this highlights the flexibility of the ptp structure.

Investing in publicly traded partnerships

investors in ptps enjoy certain benefits, primarily related to taxation and income distribution.

Tax-efficient income

since ptps do not pay corporate income tax, they can distribute a more significant portion of their income to investors compared to traditional corporations. the tax treatment of ptp distributions is advantageous as they are treated as a return of capital. this reduces the partner’s basis with each distribution and enables the use of depreciation and tax losses.

Quarterly distributions

ptps typically make quarterly cash distributions to their partners, providing a regular income stream. these distributions can be an attractive feature for income-focused investors.

Considerations for investors

investing in ptps comes with its own set of considerations. while the tax benefits are attractive, it’s important to understand the specific nature of the partnership, the industry it operates in, and its financial health.

Real-life examples of publicly traded partnerships

publicly traded partnerships (PTPs) are not just theoretical financial entities. they have a significant presence in various industries, offering investors tangible opportunities. here are some real-life examples that illustrate the diversity and relevance of ptps.

1. Energy sector PTPs

the energy sector is a prime domain for ptps, with many well-known companies structured as ptps. for instance, energy transfer LP (ET), one of the largest midstream energy companies in the united states, operates as a PTP. it engages in the transportation and storage of natural gas, crude oil, and refined products. investors in energy transfer LP receive regular cash distributions, and they benefit from the partnership’s tax-advantaged status.

2. Real estate investment PTPs

ptps are not limited to the energy sector. real estate investment trusts (REITs) often operate as ptps, providing investors with a unique way to invest in real estate. one prominent example is the blackstone group’s blackstone real estate income trust, inc. (BREIT). breit is a non-listed REIT structured as a ptp, offering investors exposure to a diversified portfolio of real estate assets, including multifamily, industrial, and office properties.

3. Natural resource extraction PTPs

natural resource extraction companies also utilize the ptp structure. one such example is alliance resource partners, L.P. (ARLP). arlp operates as a coal producer and marketer, serving various industries. investors in arlp benefit from the partnership’s tax-advantaged status, as well as regular income distributions.

Considerations for potential investors

investing in publicly traded partnerships (ptps) can be an attractive option, but it’s essential to consider various factors before making an investment decision. here are some key considerations.

1. Industry exposure

different ptps operate in various industries, such as energy, real estate, and natural resources. investors should assess their risk tolerance and investment goals, considering the specific industry exposure of the ptp.

2. Tax implications

while ptps offer tax advantages, they can have complex tax implications for investors. understanding how ptp distributions are taxed and their impact on your tax liability is crucial.

3. Risk assessment

like any investment, ptps come with their own set of risks. industry-specific risks, economic conditions, and market dynamics can affect the performance of a ptp. conduct a thorough risk assessment to gauge the potential downsides.

4. Professional advice

before investing in a ptp, consider seeking guidance from financial professionals who can help you evaluate the suitability of ptp investments based on your financial objectives and risk tolerance.

5. Diversification

diversifying your investment portfolio is a fundamental principle of risk management. consider how a ptp investment fits into your overall portfolio and whether it contributes to diversification.


publicly traded partnerships (ptps) offer a unique blend of limited partnership advantages and the liquidity of publicly traded securities. with a focus on income generated from qualifying sources, ptps provide tax benefits that can be appealing to investors. understanding the distinctions between ptps and mlps is crucial for making informed investment decisions. as always, it’s advisable to consult with financial professionals to assess the suitability of ptp investments for your financial goals.

Frequently asked questions

What is the key difference between a publicly traded partnership (PTP) and a master limited partnership (MLP)?

publicly traded partnerships (PTPs) and master limited partnerships (MLPs) are often mentioned together, but there are distinctions between the two. PTPs are characterized by actively traded ownership shares on established securities markets and must derive 90% of their income from qualifying sources. In contrast, MLPs typically involve a tiered partnership structure and may not be publicly traded. The key difference lies in their structure and tax treatment.

How are the income distributions from PTPs taxed, and what makes them tax-efficient?

income distributions from PTPs are treated differently from traditional corporate dividends. They are considered a return of capital rather than ordinary income. This treatment reduces the partner’s basis with each distribution and allows for the utilization of depreciation and tax losses. The tax efficiency of PTP income distributions makes them attractive to investors.

What industries are commonly associated with publicly traded partnerships?

PTPs often engage in businesses related to the use of natural resources, such as energy, including petroleum and natural gas extraction, as well as transportation. Additionally, they may be involved in real estate, natural resource extraction, and other industries. The energy sector, in particular, has a significant presence of PTPs.

Can individuals invest in publicly traded partnerships, and how do they go about it?

individuals can invest in publicly traded partnerships (PTPs) by purchasing publicly traded units or shares in these partnerships through brokerage accounts. PTPs are accessible to individual investors, and their tax-advantaged status can make them an appealing choice for income-focused investors.

What are the potential risks associated with investing in publicly traded partnerships (PTPs)?

investing in PTPs comes with certain risks, including industry-specific risks, economic conditions, and market dynamics. Additionally, the tax implications of PTP income distributions can be complex and may affect an investor’s overall tax liability. Understanding these risks and seeking professional advice is crucial for making informed investment decisions.

Key takeaways

  • publicly traded partnerships (ptps) are limited partnerships with shares traded on established securities markets.
  • ptps must generate 90% of their income from qualifying sources to maintain their tax-advantaged status.
  • ptps offer tax-efficient income distributions, which are treated as returns of capital.
  • investors should distinguish between ptps and master limited partnerships (mlps) and consider industry-specific risks when investing in ptps.
View article sources
  1. Publicly Traded Partnerships – Internal Revenue Service
  2. Going Public: A Beginner’s Guide to Initial Public Offerings (IPOs) – SuperMoney
  3. Publicly traded partnerships. – Govinfo