The US Tax Court's ruling in Soroban v US Internal Revenue Service (161 TC No.12) declares that distributions to a limited partner (LP) may not qualify for the s.1402 exclusion from self-employment tax, but depends on the functions the LP actually performs. Previously, the exemption has been taken to automatically apply to LP partners by state law. The ruling may encourage the US Internal Revenue Service (IRS) to audit taxpayers as part of the IRS' Self-Employment Contributions Act compliance campaign.
News Source：【McDermott Will & Emery 2023/12/01】
