News & Analysis as of

Partnerships Self-Employment Tax Self Employed

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

Allen Barron, Inc. on

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

Holland & Knight LLP

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

Holland & Knight LLP on

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

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

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

Burr & Forman

S Corporation Owners Get Less than Partnership Owners and Self-Employed Individuals under Payroll Protection Program

Burr & Forman on

The Payroll Protection Program (PPP) under the CARES Act can provide eligible businesses with a forgivable loan from the government to be used to keep and pay employees, and for certain other purposes, and to help businesses,...more

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