Self-Employment Taxes, Limited Partner Exception, Recent Cases and Future Regulations
OL1613 | On Demand Course | Update | Self-Study
Description
Many entities treated as partnerships are now under attack. The IRS claims that they have incorrectly treated their owners as "limited partners," thereby allowing them to escape self-employment taxes on their distributions. The partnerships base their positions on a law enacted way back in 1977, which has never been updated. The broad scope of the "limited partner" exception, coupled with governmental inaction over the next five decades and the IRS's recent Compliance Campaign, has led to chaos. This presentation chronicles the major events culminating in the current Tax Court disputes and forthcoming IRS regulations.
This course is part of the 2025 Tennessee Federal Tax Conference Bundle. Purchase the conference bundle here.
Credits
| Number of Credits | Type of Credits |
|---|---|
| 1.00 | Taxes |
Prices
- Member (Early Bird)
- $59.00
- Non-Member (Early Bird)
- $99.00
- Member
- $59.00
- Non-Member
- $99.00
Instructors
Hale E. Sheppard, JD, LLM
Hale Sheppard is a partner with Eversheds Sutherland. With more than two decades of experience, Hale defends clients in tax audits, appeals, and Tax Court litigation, with a focus on tax disputes, international tax, employee retention credits, qualified opportunity zones, conservation easements, and captive insurance.
Hale has a proven track record of success in the courtroom, with extensive experience litigating cases before the Tax Court, District Courts, and Federal Courts of Appeal. His deep understanding of tax law enables him to secure favorable rulings from the IRS National Office for his clients. When a private letter ruling is not required, Hale skillfully navigates other administrative remedies to achieve optimal tax outcomes.
As a prolific tax writer, Hale has authored over 300 major articles in leading law reviews and tax journals. His work is frequently cited by peers in prestigious journals, legal briefs, and books, underscoring his authority in the field.
In addition to his writing, Hale is a sought-after speaker, regularly lecturing at regional and national organizations on a wide array of tax topics.
Back to Instructors