The Soroban Case: SECA and the Limited Partner Exception

The management of funds is often conducted through entities that are legally formed as limited partnerships.  Individual partners of such partnerships may hold interests as limited partners under state law which entitles the individual to a distributive share of the partnership’s taxable income.  Generally, limited partners are not subject to self-employment taxes on their share of income from a limited partnership. However, a recent decision by the Tax Court in the Soroban case may change this view which has been held for decades. In this podcast, we discuss the facts of this case and the implication to many fund managers.