Self-Employment Tax

News & Analysis as of

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

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

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

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

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

Members of Fund Management LLC Denied Self-Employment Tax Exception

In CCA 201436049 the IRS concluded that owners of an investment fund management company LLC were not eligible for the limited partner exception to Section 1402 self-employment taxes. Ultimately the IRS found that the income...more

U.K. Autumn Statement 2013

The Chancellor of the Exchequer today delivered a 130-page Autumn Statement that contained a number of surprises, as well as expected updates on areas such as partnership taxation....more

Community Property Income Not Shared For Self-Employment Tax Purposes

A recent Tax Court case illustrates a trap for the unwary in regard to the computation of self-employment taxes. Spouses subject to community property laws obtain an interest in the assets and income of their spouses. ...more

Application of the Self-Employment Tax and 3.8% Net Investment Income Tax to Fund Managers

With the imposition of a new 3.8% “net investment income tax” (the “NIIT”) pursuant to Section 1411 of the Internal Revenue Code of 1986, as amended (the “Code”) on passive income and the imposition of an additional .9% on...more

Post-Election 2012 Tax Planning Alert: Practical Tax Planning Tips for You, Your Family and Your Business

This Alert is designed to offer easy to understand and easy to implement year-end tax strategies in times of incredible tax uncertainty. This Alert is also designed to stimulate thought and inspire action during one of the...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

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