On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more
6/3/2025
/ Appeals ,
Fund Managers ,
Income Taxes ,
Investment Funds ,
IRS ,
Limited Partnerships ,
Partnerships ,
Private Equity Funds ,
Self-Employment Tax ,
Tax Court ,
Tax Liability
A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more
Summary: The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code...more