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satisfying the qualifying income requirement is the sole test for whether an MLP is treated as a partnership for federal income tax purposes because of the importance of partnership treatment most mlps are marketed to the public on the basis of low-level opinions or a private letter ruling from the Internal Revenue Service generally law firms can determine that activity generates qualifying income with the requisite level of certainty as a result less than ten percent of all MLP initial public offerings require a private letter ruling however in some cases we do go to the IRS and ask them for a plr so what is a plr a plr is company specific guidance confirming that your activity generates qualifying income typically weamp;#39;ll submit a legal brief explaining why we believe the activity generates qualifying income the IRS has a goal of responding to that request within six months although sometimes theyamp;#39;ve been faster and sometimes theyamp;#39;ve been slower and then they in
