Prose by Tax Pros

  Ambiguity about when distributions to “limited partners” are exempt from self-employment taxes has existed for five decades. This vagueness has led to many disputes, including numerous cases now winding their way through the courts. The Tax Court has made some significant rulings already, but many of the key issues are far from resolved. This article, the latest in a series, summarizes the relevant law and regulations, describes the only precedential case on the books for many years, explains the Compliance Campaign launched by the IRS, analyzes three recent Tax Court decisions, and identifies several additional cases on the way. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.)  is a partner at Eversheds Sutherland.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.

Justified or not, some members of Congress and the IRS are passionate about eliminating tax benefits associated with Private Placement Life Insurance (“PPLI”). The problem, according to those urging a legislative change, is that only certain taxpayers are financially able to access PPLI and this limitation somehow undermines the congressional purpose for offering insurance-related tax inducements. This article, which builds on an earlier one, explains the main benefits of PPLI, chronicles major events over the past decade, and examines the draft legislation that has the potential to upend present treatment of PPLI. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.)  is a partner at Eversheds Sutherland.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.

Not long ago, it was hard to go anywhere without hearing about Opportunity Zones. Time passed, and attention waned. That will soon change, though. Why? Some taxpayers recently maximized their tax-reduction abilities, the chance to defer taxes on prior capital gains will end soon, permanent exclusion of certain passive income from taxes will be accessible in the near future, the IRS is focusing on two groups heavily involved in Opportunity Zones (i.e., high-income individuals and large partnerships), and Congress is considering changes to the rules in 2025. This article, which expands on two earlier ones, addresses these key issues and others. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.)  is a partner at Eversheds Sutherland.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.