JD Supra

A Sirius Shift: Fifth Circuit Overrules The Tax Court In Defining “Limited Partner” For Self-Employment Tax Purposes

On January 16, 2026, the Fifth Circuit decided Sirius Solutions, L.L.L.P. v. Commissioner, which vacated a prior decision of the Tax Court that had denied limited partners in a state law limited ...
JD Supra

Fifth Circuit Overturns Tax Court, Ruling in Favor of the Taxpayer in Case Evaluating Standard for Limited Partner Exception to Self-Employment Tax

The U.S. Court of Appeals for the Fifth Circuit issued a split (2-1) decision in favor of the taxpayer in Sirius Solutions, L.L.L.P. v. Commissioner on January 16, 2026, holding that the “limited ...