News & Analysis as of

Internal Revenue Code (IRC) Investment Management Tax Liability

Morrison & Foerster LLP

Tax Court’s Decision in Soroban—Potential SECA Tax Implications for Management Fee Income

On May 28, 2025, the U.S. Tax Court issued its decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban”), holding that “limited partners” of a management company organized as a Delaware limited...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Husch Blackwell LLP

U.S. Tax Court Rules That Limited Partners of an Investment Manager Are Subject to Self-Employment Tax

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On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more

Cooley LLP

Soroban: An Update After US Tax Court Ruling

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On May 28, 2025, the US Tax Court ruled that investment manager limited partners in Soroban Capital Partners were active limited partners and, as such, were ineligible for the limited partner exception to self-employment...more

Foley & Lardner LLP

YA Global Heads to Appeals Court Over Tax Court Ruling on Offshore Fund’s U.S. Activities

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Share on LinkedIn Share on Twitter Print Share by Email Share Back to top Last month, YA Global Investments, LP (the “Fund”) filed a notice of appeal to the U.S. Court of Appeals for the Third Circuit, seeking review of the...more

Nelson Mullins Riley & Scarborough LLP

Death, Taxes, and Crypto Reporting – The Three Things You Cannot Escape

The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

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Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Foodman CPAs & Advisors

Los titulares de Moneda Virtual (MV) NECESITAN MANTENER REGISTROS

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La Sección 6001 del Código de Rentas Internas requiere que los Contribuyentes mantengan libros y registros adecuados. Mantener libros adecuados y buenos registros de la MV ayudará al Contribuyente a...more

Foodman CPAs & Advisors

Virtual Currency (VC) Holders NEED to KEEP RECORDS

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Internal Revenue Code Section 6001 requires Taxpayers to maintain adequate books and records. Keeping adequate VC books and good records will assist a Taxpayer to...more

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