Fifth Circuit Rejects Tax Court's Definition of "Limited Partner" for Self-Employment Tax Purposes

02.02.26

The U.S. Court of Appeals for the Fifth Circuit ruled that the meaning of "limited partner" under Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the "Code"), is determined under state law. This ruling, Sirius Solutions LLP v. Commissioner, overturned a recent Tax Court decision, Soroban Capital Partners LP v. Commissioner. The... Continue Reading

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