In July of 2022, Soroban Capital Partners LP, an investment advisor and limited partnership, filed a petition in Tax Court to challenge the IRS’ posture that its limited partners were subject to SECA tax on their distributive shares of income. According to the petition, Soroban is a Delaware...
Discusses a relatively new and complex type of limited partnership (LP) that finances low-income-housing projects and pays profits mainly in tax credits. These units are illiquid, tough to sell on short notice; Relatively untested financial products whose risks are unknown; Created by the 1986 ...
Focuses on the invalidity of a limited partnership's (LP) election not to be treated as a partnership in the U.S. Exclusion of an unincorporated organization from the application of the provisions of Subchapter K; Requirement for the LP to file as a partnership for federal tax purposes; ...