“Limited Partner” exception to Self-Employment Tax under IRC Section 1402(a)(13)

On December 23, 2024, the Tax Court reaffirmed its interpretation of the “limited partner exception” to self-employment tax under section 1402(a)(13) of the Internal Revenue Code in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114). This decision echoes its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12) and has […]