10 January 2025
Foley Viewpoints
Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax
On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law limited partnership were subject to self-employment tax on all of their distributive share of income from the partnership.
