XYZ, Ltd., is a limited partnership with a corporate general partner and 275 limited partners, all of whom are individuals and none of whom have any other relation to the general partner, and all the limited partnership shares are currently traded on the New York Stock Exchange. Mark is one of those limited partners.

At the end of its last taxable year, XYZ distributed $10,000 of its profits to Mark. Will those profits be subject to two-tier taxation?