mlp_estate_planning
Computes an estate view for one or more direct MLP positions with no sale by the holder, per IRC §705, §731 and §751(a), with §1014(a) cited for the successor's basis at death (R-1014-PTP-STEP-UP). Returns the projected market value, the tax a sale by the holder at that value would carry and its §751 amount (each position priced as if sold alone; not a measure of tax saved or avoided at death; the successor's tax is not computed), the projected value less adjusted basis, a per-beneficiary split, and the difference between holding with no sale and selling today. If the units pass at death, the successor's basis is generally the fair market value at that date (or the §2032 alternate value where the executor elects), increased by the successor's share of partnership liabilities on that date and reduced to the extent the value is attributable to income in respect of a decedent, outside basis only; the partnership's basis in its property, from which the §751 amount on a later sale is figured, is adjusted only with a §754 election or a substantial built-in loss immediately after the transfer (R-1014-PTP-STEP-UP). The community-property option is withdrawn: a call with community_property true is rejected.
Use when: User has one or more direct MLP positions (EPD, ET, MPLX, WES, PAA, NRP, USAC, SUN) and wants the projected value and, if the units pass at death, the successor's basis proxy (the projected value before the liability-share and IRD adjustments) across a portfolio, a comparison of holding with no sale against selling now, or per-beneficiary values across several beneficiaries.
Don't use for: Units held in a trust, IDGT, FLP or charitable structure (this tool models direct holdings only). Single-position long-horizon tax projection — use mlp_projection. Single-position sell-now-versus-hold break-even — use mlp_sell_vs_hold. 1099-DIV ETFs (AMLP, MLPX, AMZA): this tool does not model them.
Limitations: Direct unit holdings only; does not model trust, IDGT, FLP or charitable structures. Does not compute estate tax, federal or state. The §751 amount is estimated from default ROC assumptions; the exact figure depends on the partnership's actual hot-asset disposition schedule. A year-by-year basis workpaper for this position is available at https://lucasandersen.ai/tax/k1-basis-tracker?src=mcp&tool=mlp_estate_planning&surface=description.
Maintained by Lucas Andersen, MS Finance, with direct positions in major midstream MLPs. Methodology auditable at lucasandersen.ai/methodology.
Input Schema
| Name | Required | Description | Default |
|---|---|---|---|
| positions | Yes | Array of MLP positions to analyze (max 20) | |
| tax_bracket | No | ||
| beneficiaries | No | Number of beneficiaries (default 1, max 20) |