CPE Catalog & Events
Webcast: Tax Tuesday With Ed Zollars - “Limited Partner, As Such”—Which Partners Qualify for the Exemption from Self-Employment Tax?
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Zoom
2.0 Credits
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.
Tax Tuesday With Ed Zollars Webcast Series 2025-26
Multiple Events Between -
Up to 20.0 Credits
Arizona Tax Workshop Series 2025-26
Multiple Events Between -
Up to 24.0 Credits