Webcast: Tax Tuesday With Ed Zollars - “Limited Partner, As Such”—Which Partners Qualify for the Exemption from Self-Employment Tax?
Overview
Looking for the full series? Register at www.ascpa.com/taxtuesdayTax Tuesday May
This month we'll navigate the complex landscape of self-employment tax for limited partners in this crucial 2-hour continuing education course. Gain essential insights into the significant legal controversy surrounding the application of self-employment tax to partners, particularly in light of recent landmark cases like the Tax Court's Soroban Capital Partners decision mandating a “functional analysis” beyond mere state-law status. Understand the high financial stakes involved due to Self-Employment Contributions Act (SECA) taxes and the ongoing uncertainty fueled by the appeal in Sirius Solutions LLLP challenging the Soroban precedent in the Fifth Circuit.
This course will delve into the statutory framework, analyze key court rulings, explore the historical context and regulatory attempts, and provide practical considerations for navigating this unsettled area of tax law, making it vital for CPAs, tax advisors, and legal professionals working with partnerships.
Highlights
- Understanding the Statutory Framework: IRC § 1402(a)(13), the general rules for partner self-employment tax, and the specifics of the limited partner exception.
- The Landmark Soroban Capital Partners Decision: The Tax Court's rejection of state-law determinism and the implementation of the "functional analysis" test.
- The Sirius Solutions Appeal: Analysis of the taxpayer's arguments against the functional analysis in the Fifth Circuit, including the interpretation of "as such" and the relevance of state law.
- Historical Context and Regulatory Limbo: The original intent of the limited partner exception, the 1997 proposed regulations, and the ongoing lack of definitive guidance.
- Practical Implications and Planning Considerations: Navigating the current uncertainty, the role of guaranteed payments, and potential future developments in this critical area of tax law.
Designed For
Any accounting professional looking to stay ahead of tax changes impacting their organizations and clients.
Notice
Live, Interactive Webcast
This event is part of the following bundles:
Leader(s):
Leader Bios
Edward K. Zollars, CPA, Thomas, Zollars & Lynch, Ltd.
Edward K. Zollars, CPA, is in public practice in Phoenix, Arizona as a partner with the firm of Thomas, Zollars & Lynch, Ltd. He has been in practice for more than 35 years, specializing in tax issues for closely held businesses and individuals. Zollars has been professionally involved with both tax and technology issues, combining the two disciplines in producing the Current Federal Tax Development Update Podcast and website, dealing with current tax issues. He has been a member of AICPA Tax Division Committees focusing on tax and technology issues and was the Tax Section’s representative on three occasions to the AICPA’s Top Ten Technologies project. He is also a member of the Phoenix Tax Workshop’s Advisory Committee and currently serves on the Tax Legislation Liaison Committee for the Arizona Society of CPAs. Zollars was selected as a Life Member by the Arizona Society of CPAs in May, 2010. Along with writing, editing and presenting courses for Loscalzo Institute, Zollars has written articles published in Practical Tax Strategies and the Tax Adviser. He has been a frequent contributor to a number of professional tax discussion groups, and served as systems operator on the AICPA’s Accountants Forum in the mid-1990s. He has spoken regularly on tax and technology topics since 1996, speaking before conferences sponsored by the AICPA and a number of state societies of CPAs.
Non-Member Price $70.00
Member Price $70.00