Tax Notes Talk Top Tax Cases of 2024, Part 1: Partnerships
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Feb 21, 2025 In this enlightening discussion, tax experts Damien Martin and Tony Nitti from EY dive into the significant tax cases of 2024, particularly focusing on partnerships. They dissect the Denham Capital Management LP v. Commissioner and Surk LLC v. Commissioner cases, exploring the implications for IRS interpretations and partnership roles. The conversation highlights the complex relationship between general and limited partners, their tax responsibilities, and recent legislative shifts impacting asset managers. Prepare for a blend of humor, insights, and practical tax discussions!
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Conspiracy Theories
- Damian Martin's absence from the podcast last year sparked conspiracy theories.
- Some speculated about diva-like demands, like no eye contact or condor egg omelets.
Medical Emergency
- Damian Martin explains his absence last year was due to a medical emergency involving meningitis.
- He spent time in neuro ICU and is now recovered.
Limited Partner Tax Exception
- Limited partners traditionally enjoyed a self-employment tax exception, but recent cases challenge this.
- The IRS argues that active LPs involved in management shouldn't qualify for the exception.