United States: Tax

The Fifth Circuit Court of Appeals has modified its stance on self-employment taxes for pass-through entity owners, moving from a simple liability-based test to a more nuanced "significance" test that examines an owner's involvement in business operations. This shift creates uncertainty for LLC and partnership owners who must now evaluate whether their management role is "significant" enough to trigger self-employment tax obligations, while traditional limited partners may still find safe harbor from these

A recent decision from the United States District Court for the Southern District of Florida offers a cautionary tale for estate planners who rely on Qualified Personal Residence Trusts (QPRTs) and the interplay between state homestead protections and federal estate tax inclusion rules.

The IRS has fundamentally transformed how it administers penalty relief for compliant taxpayers, replacing the decades-old First Time Abate program with an automatic system that eliminates the need for taxpayers to request relief they're entitled to receive.