Apache Corp. formed the first MLP in 1981 to consolidate 33 oil and gas drilling program limited partnerships
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MLPs became extremely popular in the mid-1980s, but their use waned after 1987 federal tax legislation restricted the MLP structure to businesses generating “qualifying income”
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Growth of the modern MLP structure was driven by the interaction between (i) tax requirements, (ii) Delaware partnership and LLC law, (iii) market expectations based on precedent transactions and (iv) the unique business characteristics of issuers utilizing the structure
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