News & Analysis as of

Partnerships Employment Tax

Proskauer - Tax Talks

Tax Court Holds That Active Limited Partners of State Law Limited Partnerships May Subject to Self-Employment Tax

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Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

Rivkin Radler LLP on

Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Winstead PC

[Virtual Half-Day Seminar] Real Estate Startup - April 18th, 9:00 am - 12:15 pm CST

Winstead PC on

On April 18, join Winstead attorneys Trip Dyer, Ben Gehlbach, Daniel Bell-Garcia, Jacob Loehr, Matt Dzura, and Cole Gearhart, along with Whitley Penn Partner Shea Krachek, for our Real Estate Startup half-day virtual seminar....more

Morgan Lewis

US Tax Court Will Weigh In on Self-Employment Tax for Limited Partners

Morgan Lewis on

Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit campaign with respect to the potential...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

Rivkin Radler LLP on

What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

McDermott Will & Emery

Weekly IRS Roundup October 19 – October 23, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 19, 2020 – October 23, 2020. October 20, 2020: The IRS released Announcement 20-40...more

Ballard Spahr LLP

Partners Must Pay Self-Employment Tax on Partnership Income—Even From a 'Disregarded Entity'

Ballard Spahr LLP on

The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Ballard Spahr LLP

Treating Partners as Employees – Overview and Update

Ballard Spahr LLP on

Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

Miles & Stockbridge P.C.

IRS Clarifies that Indirect Owners of Disregarded Entities Are Liable for Self-Employment Tax

The IRS recently released temporary regulations clarifying that an employee of a disregarded entity is liable for self-employment tax if the employee is a partner in the partnership that owns the disregarded entity. See...more

Proskauer - Tax Talks

New IRS Regulations Subject Certain Partners to Self-Employment Taxes

Proskauer - Tax Talks on

On May 3, 2016, the U.S. Department of the Treasury issued new temporary and proposed regulations (Temp. Treas. Reg § 301.7701-2T) addressing the tax treatment of partners of a partnership that is the sole owner of an entity...more

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