Tax Law and International Tax Law

The Second Circuit's ruling in Soroban Capital Partners LP v. Commissioner establishes that a "limited partner" must have both limited liability and no role in running, managing, or controlling the partnership to qualify for the self-employment tax exception. This decision, alongside the Fifth Circuit's revised opinion in Alain v. Commissioner, creates a circuit split with significant implications for fund managers who structure ownership through limited partnerships to minimize self-employment tax

The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.

The IRS has proposed new regulations that would impose nondiscrimination requirements on private schools seeking to maintain their tax-exempt status under section 501(c)(3). These regulations would prohibit policies discriminating on the basis of race, color, or national or ethnic origin in admissions, financial assistance, and other school programs. The proposed rules raise important questions about how private schools can structure their programs while complying with federal tax law requirements.