News & Analysis as of

Self-Employment Tax Employment Tax

Cooley LLP

Limited Partners May Be Subject to Self-Employment Tax

Cooley LLP on

On November 28, 2023, in Soroban Capital Partners LP v. Commissioner, the US Tax Court denied the taxpayer’s motion for summary judgment, holding that whether a limited partner in a state law limited partnership qualifies for...more

Proskauer - Tax Talks

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

Proskauer - Tax Talks on

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

Obermayer Rebmann Maxwell & Hippel LLP

Impactful Tax Court Decision May Now Subject “Limited Partners” to New Self-Employment Tax Burden

A U.S. Tax Court ruled on November 28, 2023, that limited partners in a partnership may be obligated to remit self-employment tax if they are not actually “limited” with respect to their involvement and relationship to a...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

Are The Feds Getting Ready To Kick Your “S”?

Rivkin Radler LLP on

Report Card- A couple of weeks ago, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report that presented the results of its review to determine whether the IRS’s “policies, procedures and,...more

Freeman Law

The Federal Tax Law and Lawyers

Freeman Law on

In many respects, operating a law firm is no different than any other business. Specifically, the law firm generates revenues through providing services to its clients and incurs various operating expenses throughout the...more

Davis Wright Tremaine LLP

IRS Provides Further Guidance on Deferring Employment Taxes Under CARES Act

As we discussed in a previous advisory, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permits employers and certain self-employed individuals to delay payment of the employer's share of Social Security...more

White and Williams LLP

CARES Act Payroll Tax Deferral: A Detailed Analysis

The Coronavirus Aid, Relief, and Economic Security Act (Act) contains several business relief provisions, including an employer payroll tax deferral (Deferral) and a companion provision allowing an employee retention credit...more

Proskauer Rose LLP

UK Tax Round Up - November 2019

Proskauer Rose LLP on

UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...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

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

Latham & Watkins LLP

Partnerships: IRS Extends Prohibition on Treating Partners as Employees

Latham & Watkins LLP on

Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more

Eversheds Sutherland (US) LLP

Neither a Partner nor Employee Be: Treasury and the IRS Issue Regulations Clarifying the Employment Tax Treatment of Partners in...

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued temporary regulations (Regulations) clarifying the federal employment tax treatment of the owners of partnerships and other entities...more

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