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Expert Analysis

IRS Memo Raises New Tax Questions For Investment Managers

Law360, New York (September 17, 2014, 12:55 PM EDT) -- On Sept. 5, 2014, the Internal Revenue Service issued Chief Counsel Advice 201436049 (CCA), concluding that members of an investment manager were subject to self-employment (SE) taxes with respect to their earnings from the investment manager.[1] Although the status of certain "limited partners" for purposes of the SE tax has been an open question for a number of years, the CCA makes clear, at least with respect to members of a limited liability company, that the IRS Office of Chief Counsel would advise field agents to challenge the status of such members for SE tax purposes....

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