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Internal Revenue Service › Fund Managers › Tax Liability

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Hogan Lovells

The limited partner exception from self-employment taxes: Soroban II

Hogan Lovells on

The latest chapter in the IRS attack on the use of a self-employment tax exception by fund managers came in the form of another Tax Court opinion last month in Soroban Capital Partners LP v. Commissioner (“Soroban II”) The...more

WilmerHale

Court Decision on Limited Partner Exception to Self-Employment Tax

WilmerHale on

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

Polsinelli

No S-Corp for You? – New Proposed Carried Interest Regulations that May Affect Crypto Fund Managers

Polsinelli on

Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

Akin Gump Strauss Hauer & Feld LLP on

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

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