Tax Law and International Tax Law

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Article
Understanding Portability For Estate And Gift Tax
Portability of estate and gift tax enables a surviving spouse to inherit any unused portion of their deceased spouse's federal estate and gift tax exemption, potentially doubling the exemption amount. While this powerful mechanism can help married couples preserve unused tax exemptions and minimize transfer tax liability, it is frequently misunderstood, underutilized, or improperly elected. Understanding the statutory framework, mechanics...
United States Tax
SH
Scarinci Hollenbeck LLC
Article
How "Limited" Is The Limited Partner Exception?
Federal courts are divided on whether the "limited partner exception" from self-employment tax applies only to passive investors or extends to all partners in limited partnerships with limited liability. With appeals pending in multiple circuits and the Fifth Circuit rejecting the Tax Court's functional analysis approach, the resolution of this controversy will significantly impact fund managers, professional service partnerships, and other passthrough business owners.
United States Tax
SJ
Steptoe LLP
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