For purposes of self-employment taxes, many members of LLCs have treated themselves as limited partners
and have therefore reported that their distributive share of income was not subject to self-employment tax under Sec.
The FLP should preserve the general partner's fiduciary duties toward the limited partners
The Partnership has rescheduled the special meeting to provide limited partners
additional time to consider and clarify their available options.
The Schedule K-1s were distributed to each limited partner
and the limited partners
used the numbers on it as deductions in filling out their individual returns.
To Initiate Foreign Limited Partners
to Potential Investment Opportunities and Expected Portfolio Risks in China's PE Market
As a consequence, the Tax Court found that A "essentially stood on all sides of the partnership's formation and approved the provisions of the KPLP agreement without negotiation or input from the limited partners
The CPA should have verified that the information, or evidence of wrongdoing was correct, and insisted that the general partners notify the limited partners
of the excess management fees.
1402(a)-2, which effectively subjected certain limited partners
(primarily LLC members) to SE taxes, Congress placed a moratorium on their finalization.
The taxpayers, who were involved in the real estate business on a full-time basis, were limited partners
in a partnership that owned and operated a shopping center.
These limited partners
want to nurture the next generation of entrepreneurs, but expect a fair rate of return on their money as well.
1402(a)-2(h)(5) and -(2)(h)(6)(iii) provide that if substantially all of a partnership's activities involve the performance of services in the fields of health, law, engineering, architecture, accounting, actuarial science or consulting, then all individuals who provided services as part of the trade or business will not he considered limited partners
The Internal Revenue Service held that LLCs may be treated as partnerships for federal tax purposes (depending on the specific provisions in the LLC's operating agreement and the applicable state law); as such, LLC members are in effect limited partners