Tax Law News and Insights

In Soroban Capital Partners LP v. Commissioner,1 the Tax Court addressed the scope of the so-called “limited partner exception” from U.S. federal self-employment tax (“SECA”). Background The tax base on which SECA applies excludes “the distributive share of any item of income or loss of a limited partner, as such.” The statute...

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State tax coffers in California keep climbing. The California Department of Tax and Fee Administration (CDTFA) has reported cannabis tax revenue for the third quarter of 2023. As of November 16, 2023, total cannabis tax revenue from third-quarter returns is $269.3 million. This includes California's cannabis excise tax, which generated...

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On November 28, 2023, in Soroban Capital Partners LP v. Commissioner, the US Tax Court denied the taxpayer's motion for summary judgment, holding that whether a limited partner in a state law limited partnership qualifies for the "limited partner" exception from self-employment tax under Internal Revenue Code (IRC) Section 1402(a)(13) depends...

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