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MASTER LIMITED PARTNERSHIPS (MLPS)
In recent years, many U.S.
energy firms have
reorganized their
slow-growing, yet stable
businesses, such as
pipelines and storage
terminals, into master
limited partnerships, or
MLPs. There are some
important differences
between buying shares of a
corporation and buying a
stake in an MLP. With MLPs,
investors buy units of the
partnership, rather than
shares of stock, and are
referred to as
"unitholders."
A. There are two classes of MLP owners: General Partners and Limited Partners.
General
Partners manage the
day-to-day operations of the
partnership. An MLP
technically has no
employees, so all services,
from management to
bookkeeping, are provided by
the general partner.
All other investors are
Limited
Partners and have no
involvement in the
partnership's operations.
Limited-partner units are
publicly traded, while
general-partner units
usually are not. The general
partner stake is often 2% of
the partnership, though the
general partner can also own
limited-partner units to
increase its percentage of
ownership. Companies that
use the MLP format tend to
operate in very stable,
slow-growing industries,
such as pipelines. These
types of firms usually offer
lower prospects for unit
price appreciation, but the
stability of the industries
that use the MLP format
means below-average risk for
investors. Cash
distributions usually stay
relatively steady over time
(often only growing at
little more than overall
inflation). Furthermore MLPs
tend to generate income
according to transport
volumes not commodity prices
so they are not a proxy for
or correlated to,
commodities.
Some benefits of MLPs include:
Relatively High
Yield. Most MLPs
offer very attractive
yields, generally in the
6%-7% range.
Consistent
Distributions Over Time.
The businesses
operated as MLPs tend to be
very stable and produce
consistent cash flows year
after year, making the cash
distributions on MLP units
very predictable.
Capital Gains.
Firms primarily switch to
the MLP structure to avoid
taxes. While shareholders in
a corporation face double
taxation--paying taxes first
at the corporate level, and
then at the personal level
when those earnings are
received as
dividends--owners of a
partnership are taxed only
once: when they receive
distributions. There is
no partnership equivalent of
corporate income tax.
Cash distributions to owners
often exceed partnership
income, and when they do,
the difference is counted as
a return of capital to the
limited partner and taxed at
the capital gains rate when
the unitholder sells. In
fact the bulk of most MLP
distributions are considered
cost basis reductions
instead of income. This
portion creates no current
tax. The current benefit
is that Capital Gains tax
rates are lower than
ordinary income. Although
this may change, deferring
taxes is generally
considered an attractive
attribute of MLPs.
Lower Cost of
Capital. The
absence of taxes at the
company level gives MLPs a
lower cost of capital than
is typically available to
corporations, allowing the
MLPs to pursue projects that
might not be feasible for a
taxable entity.
General Partner Compensation
Aligned with Limited
Partners' Interest.
Most general partners are
paid on a sliding scale,
receiving a greater share of
each dollar of cash flow as
the limited partners' cash
distributions rise, giving
the general partner an
incentive to increase
limited-partner
distributions.
B. There are of course certain downside risks to MLPs that should be considered.
Personal Tax
Liability. Each
unitholder is responsible
for paying his or her share
of the partnership's income
taxes, which can make filing
taxes more complicated. This
is particularly true for
larger unitholders, who may
have to pay taxes in the
various states in which the
partnership operates.
Moreover, limited partners
might owe taxes on
partnership income even if
the units are held in a
retirement account.
IRA or Tax Deferred
Plans. MLPs may
trigger taxation in these
types of accounts.
Limited Pool of
Investors. MLPs
face a smaller pool of
potential investors than
traditional equities because
institutional investors,
such as pension funds, are
not allowed to hold MLP
units without incurring tax
liability. These large
investors do not ordinarily
pay taxes, so they tend to
shy away from MLPs.
Institutional investors
represent the majority of
investor dollars in the
market, so eliminating them
reduces the potential demand
for MLP units. Congress
recently approved a
provision allowing mutual
funds to buy MLPs, which
should dramatically increase
the number of potential
investors.
C. Ways to gain exposure to MLPs
Investors in search of
higher income have the
opportunity to allocate a
portion of their taxable
portfolio to MLPs and they
can do it in several ways.
Purchasing direct MLPs
Purchasing an index of MLPs
When looking to an index, as
is the case for all index
investments, investors are
able to diversify away
single company risk. MLP
indexes offer this benefit
as well as unique additional
tax benefit. Investors in
MLP indexes receive the
cashlfow from the pool of
MLPs in the index. MLP Index
investors have a tax
advantage over direct
investors in MLPs. Direct
investors are actually
limited partners of the MLP
and therefore receive K1s
making tax preparation more
complex and potentially more
costly. When buying AMJ the
investor buys shares which
receive the pass-through
income which is then
reported on a 1099 form, far
easier to deal with than the
K-1 form used by limited
partnerships.
One MLP
Index worth mentioning is
the JPM Alerian MLP Index
Exchange Traded Note (Symbol
AMJ). 10 shares of AMJ equal
the Alerian MLP Index, which
is about 290. AMJ owns units
in MLPs allowing the fund to
emulate the Alerian MLP
Index. The Alerian MLP
Index has a superb track
record. In 14 years, it has
tripled with a modest to low
beta and it's only 15% below
the record high reached in
2007. The comparable Alerian
index including reinvested
income has grown almost 8
times its original value.
Currently, the yield on AMJ
is approximately 6.5%.
This Product appears to
have been issued less than
one year through JPMorgan,
however that is not entirely
true. When JPM acquired Bear
Stearns, this MLP Index Note
was a Bear Stearns product.
It is now securely anchored
by JPM, and since these type
of ETNs carry the credit
risk of the issuer, with JPM
clearly a top credit within
the global financial
services space, the credit
risk looks to be acceptable.
Below is a graph of the
historical performance of
the Alerian MLP Index.

The graph below compares the
MLP Index to the S&P 500.
Notehworthy here is the
inverse relationship between
the MLP Index and the SP500
during the period 2000-2003,
a time similar to the
current environment where
interest rate policy was
stimulative.

Also interesting is the
performance of the MLP Index
during the years 2003-20006
which were post Tech Bubble
and September 11th periods
of low then rising interest
rates. MLPs during these
years showed no correlation
to bonds (as expressed by
the BNY Intermediate Bond
Index symbol MIIDX) where
total returns for bonds were
relative flat.

The conclusion is that MLPs
offer a compelling case for
portfolio diversification
for specific types of
qualified investors. MLPs
have a lower standard
deviation than broader
equity markets and show
little correlation to fixed
income markets making them
very attractive during
periods of lower interest
rates.
With the
ability to allocate capital
to the MLP space through
index alternatives,
investors can easily
diversify away MLP specific
risk and what was once a
more complicated investment
from the perspective of tax
reporting has now become
much more simplified.
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