News & Analysis as of

Self-Employment Tax S-Corporation Asset Management

Smith Anderson

What Limited Partners Should Know About Soroban

Smith Anderson on

The Tax Court’s use of a functional analysis test to determine limited partner status in Soroban Capital Partners LP has had a ripple effect in the world of asset management. The decision’s impact will be felt in the tax and...more

Foley & Lardner LLP

Another Fund Manager Sues IRS Over Application of “Limited Partner” Exception to Self-Employment Taxes

Foley & Lardner LLP on

On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management (“Point72”) filed a petition with the Tax Court contesting the IRS’s position that its owner, billionaire and New York Mets team...more

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