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Tax Liability Self-Employment Tax

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

Rivkin Radler LLP

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

Rivkin Radler LLP on

Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...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

Neal, Gerber & Eisenberg LLP

IRS Concludes Many Airbnb-Style Rental Arrangements Are Subject to Self-Employment Tax

The ongoing COVID-19 pandemic has caused many individuals to reevaluate vacation destinations and where they choose to work. Why work in snowy Chicago during the winter months when you can perform the same work remotely in a...more

Polsinelli

IRS Advises that Virtual Currency Received in Exchange for Microtasking is Subject to Ordinary Income Tax and Self-Employment Tax

Polsinelli on

As discussed in previous blog entries , the IRS has been engaged in an ongoing campaign intended to address noncompliance related to the use of crypto currencies, including a virtual currency compliance campaign spearheaded...more

Seyfarth Shaw LLP

The Secretary of Treasury Selects April 1 as the Effective Date for purposes of the Tax Credits under the Families First...

Seyfarth Shaw LLP on

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

Akin Gump Strauss Hauer & Feld LLP

Federal Income Tax Payment and Filing Deadline Delayed to July 15 Amid COVID-19 Crisis

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

Ballard Spahr LLP

Partners Must Pay Self-Employment Tax on Partnership Income—Even From a 'Disregarded Entity'

Ballard Spahr LLP on

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

Farrell Fritz, P.C.

Self-Employment Tax, LLCs, & The “Limited Partner” Exclusion

Farrell Fritz, P.C. on

In general, self-employed individuals are subject to employment taxes on their net earnings. The wages paid to individuals who are non-owner-employees of a business are also subject to employment taxes, regardless of how...more

Farrell Fritz, P.C.

Who Is The Taxpayer?

Farrell Fritz, P.C. on

Back to Basics - This is not a silly question. In fact, it is often one of the most difficult issues confronted by a tax adviser, and it arises from one of the most basic of tax principles; specifically, that income is...more

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