August 18, 2026
A recent withdrawal and replacement of a Fifth Circuit ruling may impact certain investment fund managers’ ability to claim exemption from self-employment tax under Internal Revenue Code (“Code”) Section 1402(a)(13) on their distributive shares of management fee income.
As discussed in our previous January 2026 client alert, the Fifth Circuit delivered a significant win for investment fund managers organized as limited partners. The court overruled a Tax Court opinion and h...
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