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 ...
The Tax Court in Soroban Capital Partners LP, 161 T.C --, No. 12, Dec. 62,310, has recently addressed the issue of when limited partners may be subject to self-employment tax, or, stated another way, ...
This January, the Fifth Circuit Court of Appeals in Sirius Solutions L.L.L.P. v. Commissioner reversed a pro-IRS decision by the United States Tax Court and eased the burden of self-employment tax for ...
The IRS wants to argue that the more involved a limited partners is in the day-to-day operations of a business, the more likely they should be subject to self-employment tax. What is a limited partner ...
The answer to this previously clear-cut question has become more doubtious in recent years.Today, the answer may depend on which court hears the case and whether Congress elects to weigh in on the ...
The calculation of self-employment taxes is based on the net income earned from self-employment activities. This includes any revenue generated from business activities conducted as a sole proprietor, ...
Forbes contributors publish independent expert analyses and insights. Admitted NY Bar and US Tax Court, covers US international tax law. The U.S. Tax Court decided Soroban Capital Partners LP v.
Partnerships are not subject to income tax at the entity level. Instead, they operate as pass-through entities, meaning the partnership’s income, deductions and credits flow directly to the individual ...