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Self-Employment Tax Internal Revenue Service Income Taxes

Falcon Rappaport & Berkman LLP

For Tax Purposes, Are Limited Partners Really Limited Partners?

In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more

Allen Barron, Inc.

US Treasury Says IRS is Focused on Tax Evasion Targeting

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The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

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In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Robinson Bradshaw

Tax Court Takes Narrow View of Limited Partner Exclusion from SECA Tax

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The Tax Court, in a victory for the IRS, recently issued an opinion holding the limited partner exception to the Self-Employed Contributions Act Tax must be construed narrowly. The court held a limited partner under state law...more

Holland & Knight LLP

U.S. Tax Court: Limited Partner SECA Exception Requires Functional Analysis

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The U.S. Tax Court recently issued a precedential opinion in Soroban Capital v. Commissioner, holding that the limited partner exception to the Self-Employed Contributions Act (SECA) in Section 1402(a)(13) of the Internal...more

Cooley LLP

Limited Partners May Be Subject to Self-Employment Tax

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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

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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

Kohrman Jackson & Krantz LLP

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...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

Troutman Pepper

Tax Court Rules That Limited Partners May Be Subject to Self-Employment Tax

Troutman Pepper on

Summary - On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more

Morgan Lewis

US Tax Court Decision Opens Limited Partners to Self-Employment Tax Exposure

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Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment...more

Morgan Lewis

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

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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”?

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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

Polsinelli

IRS Advises that Virtual Currency Received in Exchange for Microtasking is Subject to Ordinary Income Tax and Self-Employment Tax

Polsinelli on

As discussed in previous blog entries , the IRS has been engaged in an ongoing campaign intended to address noncompliance related to the use of crypto currencies, including a virtual currency compliance campaign spearheaded...more

Seyfarth Shaw LLP

The Secretary of Treasury Selects April 1 as the Effective Date for purposes of the Tax Credits under the Families First...

Seyfarth Shaw LLP on

Seyfarth Synopsis: The tax credits afforded to certain employers and self-employed individuals by the Families First Coronavirus Response Act (FFCRA) are in effect for the period from April 1, 2020 to December 31, 2020. ...more

Akin Gump Strauss Hauer & Feld LLP

Federal Income Tax Payment and Filing Deadline Delayed to July 15 Amid COVID-19 Crisis

In guidance published March 18, 2020 (Notice 2020-17), the Internal Revenue Service (IRS) postponed the payment deadline from April 15, 2020, until July 15, 2020, for federal income tax payments (including payments of tax on...more

Rosenberg Martin Greenberg LLP

The Crackdown on Cryptocurrency

We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more

Lathrop GPM

Digital Assets and the IRS

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Within the past year, the IRS has not changed its position on the way they are treating the taxation and reporting of digital token transactions. This alert serves as an update to last year’s rundown of cryptocurrency...more

Ballard Spahr LLP

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

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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

Foodman CPAs & Advisors

IRS is on to Self-Employed Taxpayers

On February 14, 2019, the TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION (TIGTA) released the Report “Expansion of the Gig Economy Warrants Focus on Improving Self-Employment Tax Compliance”. ...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

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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

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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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