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Internal Revenue Service › Self-Employment Tax › Investment Management

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Tannenbaum Helpern Syracuse & Hirschtritt LLP

Investment Fund Manager Update on Self-Employment Limited Partner Exception: Tax Court Holds that Limited Partners May Be Subject...

Tannenbaum Helpern Syracuse & Hirschtritt LLP on

On November 28, 2023, the Tax Court held that limited partners in state law limited partnerships cannot automatically rely on Section 1402(a)(13) of the Self-Employment Contributions Act (“SECA”) to exclude their distributive...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

Seward & Kissel LLP on

Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

Cadwalader, Wickersham & Taft LLP on

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more

Jackson Walker

IRS: Investment Fund Managers are Subject to Self-Employment Tax

Jackson Walker on

The Office of Chief Counsel of the Internal Revenue Service (the "IRS") recently issued internal guidance in the form of a Chief Counsel Advice (the "CCA") indicating that the IRS has taken the position that the "limited...more

Katten Muchin Rosenman LLP

IRS Considers Whether Management Fees of an LLC Are Subject to Self-Employment Tax

Katten Muchin Rosenman LLP on

A recent response by the Internal Revenue Service Chief Counsel (CCA) to an inquiry from one of its field office agents addressed the question of whether management fees earned by an investment manager organized as a limited...more

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