A recent U.S. Tax Court decision provides clarity to what the Internal Revenue Service (“IRS”) considers a limited partner for purposes of the ‘limited partner exception’ to the Self-Employment Contributions Act (“SECA”) tax...more
In September, Treasury announced forthcoming guidance that will clarify whether the limited partner exception applies to limited partners that actively participate in their businesses....more
Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more
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
Taxpayers are once again challenging the IRS’s position that a partner cannot wear two hats (i.e., service provider and investor) and still qualify as a limited partner for Self-Employment Contributions Act (“SECA”) purposes....more
The ongoing COVID-19 pandemic has caused many individuals to reevaluate vacation destinations and where they choose to work. Why work in snowy Chicago during the winter months when you can perform the same work remotely in a...more
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 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
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
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
In general, self-employed individuals are subject to employment taxes on their net earnings. The wages paid to individuals who are non-owner-employees of a business are also subject to employment taxes, regardless of how...more