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Agriculture Conference 2016


12 - Killing Two [Tax] Birds With One [Definitional] Stone


May 20, 2016 11:15am ‐ May 20, 2016 12:30pm

Standard: $49.00

Description

Proposed regulations released in 1997 under the self-employment tax attempted to define the term “limited partner” for self-employment tax purposes. The IRS informally stated that it will respect the proposed regulations as authority. Using spousal attribution in passive activity regulations, NIIT exposure may also be reduced. During the session, participants will:
• Learn of the opportunities to structure partnerships to exclude income from both the self-employment tax and net investment income tax
• Understand the definition of “limited partner” for self-employment tax purposes when an LLC is used
• Recognize when an owner is nonpassive with respect to an activity

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