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.
The “UP-C” Structure
2015 saw continued use in initial public offerings of the “UP-C” (or Umbrella Partnership–C-Corporation) structure. In this 10-minute podcast, corporate partner Josh Bonnie and John Hart, head of Simpson Thacher’s Tax Department, explain the basics of this structure and the associated tax receivable (TRA) arrangements.
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: