The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
The Internal Revenue Service (“IRS”) audits 1% to 2% of small business income tax returns annually for one of two reasons: (1) something about the return (or information reported on the return) flagged the return for a closer...more
Welcome to the January 2026 edition of The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. ...more
“[E]ase of administration cannot justify reading limitations into a statute that the legislature did not adopt.” So stated the Court of Appeals of the State of Washington when it ruled that a manufacturer was entitled to a...more
Over their career, every tax practitioner has had many client-taxpayers against whom a government’s taxing authority – be it federal, state, or local – has asserted and then assessed a tax deficiency. There are many...more
New Jersey taxpayers continue to face one of the highest real estate tax burdens in the nation. The state’s high tax rates, coupled with fears of an economic downturn, increased tenant vacancies and high interest rates, can...more
A recent federal court decision furnishes limited partners with a significant tax victory. The Fifth Circuit Court of Appeals recently decided that limited partners are eligible for the self-employment tax exclusion under...more
The U.S. Court of Appeals for the Fifth Circuit ruled that the meaning of “limited partner” under Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”), is determined under state law. ...more
In the latest self-employment tax ruling, the Fifth Circuit Court of Appeals issued a ruling in Sirius Solutions, L.L.L.P. v. Commissioner (the “Ruling”) that will ultimately permit state-law limited partners to exclude their...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On January 16, 2026, in Sirius Solutions v. Commissioner, the U.S. Court of Appeals for the Fifth Circuit held that limited partners in a partnership may qualify for an exemption from self-employment tax on their distributive...more
On January 16, 2026, in Sirius Solutions, L.L.L.P. v. Commissioner, No. 24-60240 (5th Cir. Jan. 16, 2026), the U.S. Court of Appeals for the Fifth Circuit reversed the Tax Court and held that, for self-employment tax...more
In the summer of 2025, we issued an alert on this subject, U.S. Tax Court Issues Ruling on Self-Employment Tax Exception for Limited Partners (06.11.2025). The case discussed in that alert was the third of a series of...more
This January, the Fifth Circuit Court of Appeals in Sirius Solutions L.L.L.P. v. Commissioner reversed a pro-IRS decision by the United States Tax Court and eased the burden of self-employment tax for passive owners in...more
There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more
On January 16, 2026, the United States Court of Appeals for the Fifth Circuit issued a ruling defining the term “limited partner” as used in the Internal Revenue Code of 1986, as amended (the “Code”). The Court held that a...more
On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit decisively rejected the IRS’ attempt to narrow the definition of “limited partner” for purposes of the self-employment tax exclusion under section...more
In a significant decision for the investment funds industry, the U.S. Court of Appeals for the Fifth Circuit has officially rejected the Internal Revenue Service (IRS)’s “passive investor” test for the limited partner...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we briefly summarize selected state and local tax (SALT)...more
On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit issued a closely watched decision in Sirius Solutions, L.L.L.P. v. Commissioner (“Sirius”), vacating and remanding the Tax Court’s holding that certain...more
The House of Representatives recently passed H.R. 5346, the “Fair and Accountable IRS Reviews Act,” with strong bipartisan support. The legislation seeks to address long-standing challenges in tax administration. If enacted...more
The U.S. Court of Appeals for the Fifth Circuit issued a split (2-1) decision in favor of the taxpayer in Sirius Solutions, L.L.L.P. v. Commissioner on January 16, 2026, holding that the “limited partner exception” to...more
On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit rejected the “Passive Investor” test used by the Tax Court in Soroban Capital Partners LP v. Commissioner (“Soroban”) and determined that limited partners...more
On January 16, 2026, the US Court of Appeals for the Fifth Circuit became the first federal appellate court to interpret the “limited partner” exception from self-employment tax under Section 1402(a)(13) of the Internal...more
On December 1, 2025, the House of Representatives passed H.R. 5349, the “Tax Court Improvement Act,” with bipartisan support. The bill seeks to modernize several historically challenging aspects of tax administration. As...more
Last week, the federal Court of Appeals for the Fifth Circuit ruled that the U.S. Tax Court had misinterpreted the Code’s self-employment tax rules as they apply to individuals who hold limited partnership interests in a...more