The Advanced Tax Strategy Series: Entity Selection: Payroll Taxes in the Era of Soroban Capital Partners and Sirius Solutions

Matthew Foreman discusses Soroban Capital Partners LP v. Comm’r and Sirius Solutions LLLP v Comm’r, which deal with the imposition of self-employment taxes, focusing on the ongoing tax saga of a hedge fund partners trying to convince the IRS that they are “limited partners, as such”. This will (hopefully) include the results from the en banc Second Circuit hearing for Soroban, and is for anyone who is starting, operating, structuring, or wondering about how income tax structuring interplays with other kinds of taxes.