PRESENTED AT. LLCs, LPs and Partnerships July 13-14, 2017 Austin, Texas HELLO! INADVERTENT PARTNERSHIPS

Similar documents
Management Provisions: Pros and Cons of Manager Managed v. Member Managed

Personal Liability for Tax Assessments of a Business

DRAFTING IMPLICATIONS OF THE BUSINESS ORGANIZATIONS CODE IMPACT ON DRAFTING OF AGREEMENTS

Update from the Secretary of State s Office

Fixing or Killing Off Broken Trusts

The Use and Enforceability of Liquidated Damage Clauses

Tax Planning for S Corporations: Mergers and Acquisitions Involving S Corporations (Part 1)

Jessica Galligan Goldsmith:

CONFLICTS ISSUES FOR LARGE LAW FIRMS

DELAWARE UPDATE 2006 LEGISLATION AMENDING CERTAIN ALTERNATIVE ENTITY LAWS. Norman M. Powell, Esquire *

FIDUCIARIES GONE WILD: Fiduciary Risk Management for Individual Executors, Trustees and Other Fiduciaries

Right To Do Or Do It Right? Trust Ownership of Family Businesses

CASE LAW UPDATE: A SURVEY OF RECENT TEXAS PARTNERSHIP AND LLC CASES

HOW TO MAKE THE TRUSTEE HAPPY AND KEEP YOUR CLIENT OUT OF TROUBLE

Pickle People: Using the Pickle Amendment to Obtain Medicaid Eligibility

S. Stacy Eastland Houston, Texas

TITLE INSURANCE: CLOSING PROTECTION LETTERS

Anti-Corruption and Other Compliance I ssues

Disclaimers under the New Texas Uniform Disclaimer of Property )nterests Act

Bobbie J. Collins. Associate. P / F

Transactional Scoping and Approvals

2005 William and Mary Tax Conference Speakers

INSURANCE PROVISIONS AND CASUALTY LOSSES

NO CV IN THE COURT OF APPEALS FIFTH JUDICIAL DISTRICT OF TEXAS DALLAS, TEXAS

Shelter from the Gathering Storm: Protection for Trustees (and Their Lawyers!) Facing Fiduciary Challenges

Court of Appeals Ninth District of Texas at Beaumont

Tax Planning for S Corporations: Mergers and Acquisitions Involving S Corporations (Part 2)

WHITE PAPER AN EXECUTIVE SUMMARY FOR COMMUNITY BANKERS VOLUME 19 AUGUST New Developments in Overdraft and Account Processing

Update from the Office of the Secretary of State

In The Court of Appeals Fifth District of Texas at Dallas. No CV. DAVID MILLS, Appellant V. ADVOCARE INTERNATIONAL, LP, Appellee

POTENTIAL BROKER-DEALER PITFALLS FOR PRIVATE INVESTMENT FUNDS AND THEIR MANAGERS

By: Michael J. Gartland (Copyright 2016 ) THIS IS AN ADVERTISEMENT.

IN THE SUPREME COURT OF TEXAS

CASE LAW UPDATE: A SURVEY OF RECENT TEXAS PARTNERSHIP AND LLC CASES

Teaching Awards Professor of the Year 2004 & 2010 (selected by graduating classes)

Do you recognize any non-profit entities other than traditional non-profit corporations and association?

John B. Snyder, III 1420 North Charles Street, AL 411 Baltimore, Maryland (410)

Walter D. Schwidetzky 1420 N. Charles St. Baltimore, MD

ATTORNEY GENERAL OF TEXAS. September 7, 2011

Fourteenth Court of Appeals

(November 2014) CURRICULUM VITAE GEORGE A. NATION III

Frederick N. Widen Partner

The Business Divorce: Maximizing Value For Clients in Property Settlements Houston Bar Association - Family Law Section, October 7, 2015

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

BUSINESS ENTITIES: Schedule C Requirements

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FIFTH DISTRICT JULY TERM v. Case No. 5D

Ohio Tax. Workshop U. Advanced: The Taxation of Technology. Tuesday, January 23, :15 p.m. to 5:15 p.m.

IN THE TENTH COURT OF APPEALS. No CV

JUDICIAL DISSOLUTION IN LIMITED LIABILITY COMPANIES: SO WHAT S HAPPENING IN TENNESSEE?

RONALD H. JENSEN. Visiting Professor of Law, Washington and Lee School of Law

LIMITED LIABILITY ENTITIES 2013 UPDATE

SUPREME COURT OF THE UNITED STATES

Setcavage Consulting LLC. Grant Building, Suite Grant Street Pittsburgh, Pennsylvania Biography and Curriculum Vitae

Foreign Language Disclosure Matrix

Distressed Investing 2012 Maximizing Profits in the Distressed Debt Market

UPDATE ON INSURANCE CODE ON DECEPTIVE, UNFAIR, AND PROHIBITED PRACTICES

Workshop S. U.S. Supreme Court Decision on South Dakota v. Wayfair, Inc. Major Direct Tax Ramifications

Understanding Charitable Trusts

IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE DECEMBER 2, 2008 Session

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

Alan Newman Curriculum Vitae December The University of Akron School of Law

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

Knight Time for Investment Fees in Trusts January 17, 2008

UNIFORM INSURABLE INTERESTS RELATING TO TRUSTS ACT (Amendment to Uniform Trust Code)

STATE OF ARKANSAS DEPARTMENT OF FINANCE & ADMINISTRATION OFFICE OF HEARINGS & APPEALS ADMINISTRATIVE DECISION

What s Different About International Arbitration? Practical Tips for Lawyers and Arbitrators

State & Local Tax Alert

Teaching Awards Professor of the Year 2004 & 2010 (selected by graduating classes)

Taxation shall be equal and uniform

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

CAUSE NO. TEXAS ASSOCIATION OF IN THE DISTRICT COURT FOR THE HEALTH PLANS, Plaintiff, 419TH vs. JUDICIAL DISTRICT. Defendant. TRAVIS COUNTY, TEXAS

Limited Liability Companies

The History of Article of the Texas Insurance Code

A Checklist for Commercial Loans

BUSINESS ENTITIES IN TEXAS 2011 TEXAS LEGISLATURE LEGISLATIVE CHANGES AFFECTING BUSINESS ENTITIES TEXASBARCLE WEBCAST AFTER.

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

Are there limitations regarding when the level of compensation for the mayor or a councilmember may be set or changed?

STATE OF TENNESSEE OFFICE OF THE ATTORNEY GENERAL. June 29, Opinion No

Secured Lending to Series of LLCs: Beware What You Do Not (and Cannot) Know

Presented: 31 st Annual Nonprofit Organizations Institute January 15-17, 2014 Austin, TX. UPMIFA: Endowment Management in the Modern Age.

INTRODUCTION (LEGAL)

IN THE SUPREME COURT OF TEXAS

Sally Harpole 何蓉. International arbitrator, mediator and attorney with over 40 years of experience in Asia.

Texas Blue Sky and Federal Securities Laws as to Oil & Gas Investments (or, We Are All Securities Lawyers Now, with apologies to Milton Friedman.

ATTORNEY GENERAL OF TEXAS

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON September 19, 2001 Session

Litigation Update for Texas Taxpayers and Research Association (TTARA) Annual Meeting

PRESENTED AT. August 3 4, 2017 Galveston, TX. Hot Topics. Speaker: Mary Alice Jackson, Esq.

Major: Political Science Phi Beta Kappa. Dean s List (all semesters) McGill Award highest achievement in Political Science

Texas Margin Tax Update

D&O 101: When the CEO Asks: Am I Covered for This?

A LLEN D. M ADISON 414 E. CLARK ST., VERMILLION, SD (W)

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

State Tax Return (214) (214)

CURRICULUM VITAE. SHARON L. McCARTHY (212)

Supreme Court of the United States

Fourteenth Court of Appeals

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

UNDERWRITING REQUIREMENTS

Transcription:

PRESENTED AT LLCs, LPs and Partnerships July 13-14, 2017 Austin, Texas HELLO! INADVERTENT PARTNERSHIPS JOHN C. ALE Senior Vice President, General Counsel & Secretary Southwestern Energy Company Copyright 2017 by John C. Ale All right reserved The views in this paper are those of the author and not necessarily those of his employer.

TABLE OF CONTENTS I. Introduction... 1 II. Basic Principles... 1 A. Definition of partnership... 1 B. Factors indicating partnership... 2 C. Factors that, by themselves, do not indicate a partnership... 3 D. Results of being a partnership... 4 III. Cases of Inadvertent Partnership... 5 A. You can t pay me? I ll sue your partner.... 5 B. You re a co-owner, so you re a partnership.... 6 C. We both filed tax returns showing income from the business. Don t say I m not your partner.... 6 D. You called me your partner after I started working with you. Now I want to be treated like one.... 7 E. We worked together under contracts that did not say we were partners but guess what: We are!... 9 F. I know we said we aren t partners and we re not bound till our boards approve and we sign big, fancy agreements but guess what: We are!... 10 IV. Conclusion: Suggestions If You Do Not Want to Be a Partnership... 12 The views expressed in this paper are those of the author and do not necessarily reflect the views of his current or former employers or law firms. Portions of this paper are derived from the author s book Partnership Law for Securities Practitioners (2016-17 ed.), part of West s Securities Law Handbook Series, with the permission of Thomson/Reuters. Copyright 2016. For further information about this publication, please visit http://store.westlaw.com/ or call 800-328-9352. i

John C. Ale Senior Vice President, General Counsel & Secretary Southwestern Energy Company John Ale is Senior Vice President, General Counsel & Secretary of Southwestern Energy Company, an energy company listed on the New York Stock Exchange whose wholly-owned subsidiaries engage in natural gas and oil exploration, development and production, along with natural gas gathering and marketing. It is the third largest natural gas producer in the Continental United States. Additional information on the company can be found at www.swn.com. Prior to joining Southwestern Energy, John was Vice President and General Counsel of Occidental Petroleum Corporation. Before that he was a partner with Skadden, Arps, Slate, Meagher & Flom LLP in the firm s energy and infrastructure projects practice group and leader of the firm s Houston office. From 1998 until 2002, he served as Executive Director and General Counsel of Azurix Corp., a global water company listed on the NYSE. Previously, he was a partner with Vinson & Elkins L.L.P., including time as head of the firm s London office and its project finance practice. He also served as a law clerk to Chief Justice Warren E. Burger at the Supreme Court of the United States and Judge Edward Allen Tamm of the U.S. Court of Appeals for the District of Columbia Circuit. John graduated from the University of Virginia School of Law (Order of the Coif, Virginia Law Review) and College of Arts and Sciences (B.A. in economics with highest honors, Phi Beta Kappa). John is a former Chair of the 4,000+-member Business Law Section of the State Bar of Texas, for which he also chaired committees on partnership law and choice-of-law legislation. He is a frequent lecturer and author on topics in energy and partnership law and on professional ethics. John is a former adjunct professor of law at the University of Texas and the author of Partnership Law for Securities Practitioners (West Securities Law Series). John has served on the Alexis de Tocqueville Committee of the United Way of Greater Houston and as a trustee of The Regis School. He and his wife live in Houston and have two grown sons. ii

I. Introduction The partnership what we often call a general partnership is the law s default business entity. When starting a business enterprise, one can choose from a wide menu of possible forms, from corporations to limited partnerships to limited liability companies to business trusts. Forming one of these other entities typically requires some formal action, such as filing a certificate of formation with a governmental agency in Texas, the Secretary of State. 1 Yet when people or entities associate to carry on a business for profit as co-owners and do not create some other entity, they are a partnership. 2 This paper discusses situations in which individuals or entities, through their words or dealings, may wind up being treated as having formed a partnership even though they did not explicitly say they were doing so. A party dealing with another may seek to characterize their relationship as a partnership to take advantage of business opportunities or to impose fiduciarytype duties on the other party. Similarly, someone dealing with a party who is not solvent may seek to characterize the insolvent party s relationship with another as a partnership so that the other, solvent party becomes liable for the debts and obligations of their purported business. These rules often are applied in hindsight. Practitioners and their clients must be careful in how they document their relationship and how they hold themselves out to third parties. II. Basic Principles A. Definition of partnership Section 152.051(b) of the Texas Business Organizations Code ( TBOC ) defines a partnership as follows: Except [for other entities created under the TBOC, other listed statutes or their non-texas counterparts, such as corporations and limited liability companies, or if the person lacks legal capacity to be a partner], an association of two or more persons to carry on a business for profit as owners creates a partnership, regardless of whether: 1 E.g., TEX. BUS. ORGS. CODE 1.002(22) (hereinafter referred to as the TBOC) (defining filing entity as a corporation, limited partnership, limited liability company or one of several other types of entities), 3.001 (forming a filing entity requires filing a certificate of formation). This paper refers to cases and statutes principally from Texas. Nevertheless, because Texas and most states general partnership statutes are based on some version of the Uniform Partnership Act issued by the National Conference of Commissioners on Uniform State Laws, UNIF. PARTNERSHIP ACT (1997), the relevant statutory language is essentially the same throughout the United States except Louisiana. 2 TBOC 152.051. This and related provisions of the TBOC were taken essentially verbatim from the Texas Revised Partnership Act, TEX. REV. CIV. STAT. ANN. arts. 6132b-1.01 to -11.05 (superseded by chapter 152 and related provisions of the TBOC for partnerships formed on or after January 1, 2006, and for all other partnerships effective January 1, 2010 or such earlier date, if any, as the partnership may have specified). Precedents under the Texas Revised Partnership Act should apply under the TBOC s partnership provisions. 1

(1) the persons intend to create a partnership; or (2) the association is called a partnership, joint venture, or other name. 3 Note that this definition: Does not require a written or even oral agreement, although association implies some sort of understanding Does not require the participants to identify themselves as partners Does not require that business actually be conducted, but only that they associate[e]... to carry on a business Does require the business be intended for profit 4 Does require association as owners and not in some other relationship; e.g., employeremployee, lender-borrower, landlord-tenant 5 As noted in the comments to the Uniform Partnership Act the model act on which Texas s partnership statute is based this definition is an operative rule of law. 6 B. Factors indicating partnership Section 152.052(a) of the TBOC lists several factors in determining whether a partnership has been formed: Receipt or right to receive a share of profits of the business Expression of intent to be partners in the business Participation or right to participate in control of the business 3 TBOC 152.051(b) (emphasis added). 4 See MT Falkin Investments, L.L.C. v. Chisholm Trail Elks Lodge No. 2659, 400 S.W.3d 658 (Tex. App. Austin 2013, pet. denied) (groups associating for nonprofit purposes do not create a partnership). 5 E.g., Bass v. Bass, 814 S.W.2d 38, 41 (Tenn. 1991) ( a contract of partnership, either express or implied, is essential to the creation of partnership status ); Ingram v. Deere, 288 S.W.3d 886, 893-94 (Tex. 2009) (partnership presupposes an agreement); Bohatch v. Butler & Binion, 977 S.W.2d 543, 544 (Tex. 1998) ( [p]artnerships exist by agreement of the partners ). For a more detailed discussion of these factors, see J. ALE, PARTNERSHIP LAW FOR SECURITIES PRACTITIONERS 2:2 (2016-17 ed.). 6 UNIF. PARTNERSHIP ACT (1997) 202 comment 1. Because the partnership provisions of the TBOC derive from the Uniform Partnership Act, a court should construe these provisions to effect its general purpose to make uniform the law of those states that enact it. TEX. GOV T CODE 311.028. See TBOC 1.051 (Code Construction Act applies to the TBOC). 2

Find the full text of this and thousands of other resources from leading experts in dozens of legal practice areas in the UT Law CLE elibrary (utcle.org/elibrary) Title search: "Hello" Inadvertent Partnerships Also available as part of the ecourse Answer Bar: LLCs and Partnerships Formation First appeared as part of the conference materials for the 26 th Annual LLCs, LPs and Partnerships session ""Hello" Inadvertent Partnerships"