News Updates

We Stay Up-To-Date on Flow-Through Tax News and Precedents So You Don't Have To.

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Another §1402(a)(13) SE Tax Case with Some Twists

06/03/2025
News

Last week, a taxpayer filed a petition with the Tax Court in Stelliam Investment Management LP v. Commissioner (Dkt. No. 7843-25; May 29, 2025), yet another investment manager case in which the IRS has denied the availability of the limited partner self-employment tax exclusion contained in §1402(a)(13).

05/29/2025
News

Yesterday, the Tax Court issued its taxpayer-adverse decision in Soroban Capital Partners LP v. Commissioner, TC Memo 2025-52 (May 28, 2025). Surprise! Surprise!

05/27/2025
News

One obvious advantage of an asset purchase when acquiring a business, as opposed to the acquisition of stock, is the ability to amortize the portion of the purchase price allocated to intangible assets pursuant to §197. However, the advantage is somewhat ameliorated on a subsequent disposition of the purchased assets because such amortization is subject to §1245 ordinary income recapture. Given that §197 became effective for intangible asset acquisitions beginning on August 11, 1993, i.e., 32 years ago, there are many “second generation” dispositions of these intangible assets. However, is recapture of the full amount of amortization deductions always the case?

05/19/2025
News

We’re avoiding commenting on the pending tax legislation, as the rhetoric by the major tax-reporting publishers is doing just fine and the Senate has not yet weighed in.

05/12/2025
News

If you are advising clients on estate planning strategies involving family limited partnerships (FLPs ), the recent Tax Court decision in Estate of Fields v. Commissioner, TC Memo 2024-90 deserves your attention.

04/21/2025
News

On April 17th, the IRS issued Notice 2025-23 announcing the intent of the IRS and Treasury to remove basis-shifting transactions as transactions of interest that require reporting under Reg. §1.6011-18 and not to issue proposed related-party basis adjustment regulations, as had been announced in Notice 2024-54.

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None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.