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Income Taxes › Tax Planning › Limited Partnerships

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Falcon Rappaport & Berkman LLP

For Tax Purposes, Are Limited Partners Really Limited Partners?

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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

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

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

Kohrman Jackson & Krantz LLP

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

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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

Troutman Pepper

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

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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

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

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Best way to structure your business to own multiple businesses in real estate and investment activities. Key benefits: Management and Control, Asset Protection, No FICA and Medicare Withholding and Ability to stagger a tax...more

Nossaman LLP

California FTB Answers the Question: Does an “LP Nothing” Really Matter?

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Anyone could see that, for a limited partnership (“LP”) that was a “tax nothing” – i.e., one “disregarded” for federal income tax purposes – the corresponding California treatment was very confusing. To clear up this...more

White and Williams LLP

Designing Tax Efficient Business Transactions

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There is an old joke that a camel is a horse that has been designed by a committee. We all know that it isn’t true. In fact, camels are horses that have been bred for maximum tax efficiency. Tax efficiency is the benign term...more

Foodman CPAs & Advisors

Taxes in Florida

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The Sunshine State is one of the lowest tax burden states in the US. Florida has no state individual income tax. At the state level, there is NO tax on social security benefits, retirement income, IRAs, 401(k) accounts,...more

Troutman Pepper

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

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More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

Foodman CPAs & Advisors

Do you know which Business Structure to choose when starting a New Business?

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When opening a new business, electing a business structure is an important decision. The business structure elected can affect how much will be paid in entity income taxes, record-keeping requirements, how much personal ...more

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