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Limited Partnerships › Business Entities › Tax Liability

Stinson LLP

U.S. Tax Court Issues Ruling on Self-Employment Tax Exception for Limited Partners

Stinson LLP on

On Wednesday, May 28, the U.S. Tax Court ruled in Soroban Capital Partners LP v. Commissioner that a "functional analysis" test applies when determining whether a limited partner who contributes services to a partnership may...more

Cadwalader, Wickersham & Taft LLP

Tax Court Affirms “Functional Analysis” Test for Limited Partner Status

Cadwalader, Wickersham & Taft LLP on

On December 27, the U.S. Tax Court issued an opinion declining to revisit its holding from 13 months earlier that a partner’s formal status as a “limited partner” under state law does not determine whether the partner is...more

Snell & Wilmer

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Snell & Wilmer on

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

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