The Limited Partner Exception to SECA Taxes: Three Tax Court Decisions and Future Clashes

 


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.


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