April 30, 2024
Tax Partner James Philbin examines SECA compliance for The Mann Report
The Mann Report
By James Philbin, Partner, Tax & Business Services
Excerpt:
In light of the Tax Court’s refusal to grant summary judgment in Soroban Capital Partners et al. v Commissioner, real estate partnerships must approach the categorization of partnership income and guaranteed payments with caution. While a partner’s share is often exempt from self-employment (SE) tax, the November 2023 ruling brings attention to the Self-Employed Contributions Act (SECA) tax compliance and the IRS’s heightened scrutiny on this issue.
