Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more
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
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
On November 28, 2023, the US Tax Court granted partial summary judgment in favor of the Internal Revenue Service (IRS) in Soroban Capital Partners LP v. Commissioner and held that “limited partners” are defined...more
On September 29, 2023, Treasury released the 2023-2024 Priority Guidance Plan, which included “Guidance under section 1402(a)(13),” signaling the government’s intention to finally clarify the confusion surrounding the limited...more
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
On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more
Seyfarth Synopsis: The tax credits afforded to certain employers and self-employed individuals by the Families First Coronavirus Response Act (FFCRA) are in effect for the period from April 1, 2020 to December 31, 2020. ...more
In guidance published March 18, 2020 (Notice 2020-17), the Internal Revenue Service (IRS) postponed the payment deadline from April 15, 2020, until July 15, 2020, for federal income tax payments (including payments of tax on...more
The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...more
Important guidance on the deduction applicable to certain business income of passthrough entities available under last year's tax reform. The U.S. Department of Treasury and Internal Revenue Service released proposed...more
On May 3, 2016, the U.S. Department of the Treasury issued new temporary and proposed regulations (Temp. Treas. Reg § 301.7701-2T) addressing the tax treatment of partners of a partnership that is the sole owner of an entity...more
Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more
In Depth - The IRS and US Department of Treasury have issued final and temporary regulations which address benefit and self-employment tax issues regarding partners in a partnership which is the sole owner of a second,...more
The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued temporary regulations (Regulations) clarifying the federal employment tax treatment of the owners of partnerships and other entities...more
On May 20, 2015, Rep. Erik Paulsen (R. Minn.) introduced the Independent Contractor Tax Fairness and Simplification Act of 2015 (HR 2483), a bill that is identical to the bill of the same name that he introduced in 2012 (H.R....more