Limited Partner Exception to Self-Employment Taxes: Where Things Stand After a Half-Century of Fighting

Overview

Many entities treated as partnerships are now under attack. The IRS claims that they have incorrectly treated their owners as “limited partners,” thereby escaping self-employment taxes on their distributive shares. This session will analyze the root of the issue in 1977, relevant IRS and court rulings over the following decades, current Compliance Campaign, recent tax court decisions, pending cases with the U.S. Court of Appeals and what it all means for partner characterization in the future.