News & Analysis as of

Limited Partnerships Appeals Investment Funds

Proskauer - Tax Talks

The Tax Court in Soroban Holds that Limited Partners Were Too Active To Be Treated As “Limited Partners” and are Subject to...

Proskauer - Tax Talks on

On May 28, 2025, in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban II”), the Tax Court held the active role of limited partners in a fund manager caused them to fail to qualify as “limited partners”...more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

White & Case LLP

The IRS Continues Winning Self-Employment Contributions Act (SECA) Tax Against Limited Partners in Private Equity and Hedge Funds

White & Case LLP on

Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...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

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