13 February 2017 Internal T.I. 2015-0568011I7 - Classification of Florida LLLP -- summary under Corporation

After providing a detailed description of the relevant provisions of the Florida Revised Uniform Limited Partnership Act of 2005 respecting LLLPs, including distinct entity status, perpetual duration and limited liability of the general partner, the Rulings Directorate concluded that two Florida real estate LLLPs had been corporations, but nonetheless suggested that they be treated as partnerships for the years in question given the transitional relief announced in 2016-0642051C6,