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Internal Revenue Code (IRC) Self-Employment Tax Tax Liability

Gray Reed

Tax Court Finds that SECA Limited Partner Exception Requires ‘Functional Analysis Test’

Gray Reed on

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

Cadwalader, Wickersham & Taft LLP

Guidance on Limited Partnership Exception May Include a Functional Analysis Test

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

Cadwalader, Wickersham & Taft LLP

Case May Bring Clarity on Self-Employment Tax on Limited Partners

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

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