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March 28, 2024
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...
February 6, 2024
The Tax Court, in a victory for the IRS, recently issued an opinion holding the limited partner exception to the Self-Employed Contributions Act Tax must be construed narrowly. The...
January 15, 2024
Hedge funds and private equity groups have long used the “limited partner exception” to minimize self-employment taxes, but on March 13, 2018, the IRS announced that it was going to...
December 6, 2023
Summary - On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state...
March 14, 2023
Private equity, hedge fund, and other investment fund sponsors should be aware that there continue to be significant developments in the Internal Revenue Service's (IRS’s) audit...
October 25, 2022
Global AI-powered Order-to-Cash platform, Sidetrade, has launched its first North America partnership with national IT consulting services firm, Sirius...