SECA Taxes, Limited Partner Exception Current IRS Disputes Analyzing the Journey to Chaos
OL968 | 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 SECA taxes on their distributive shares. The partnerships base their position on a law enacted in 1977, which has never been updated, by Congress or the IRS. The broad scope of the "limited partner" exception, coupled with governmental inaction for five decades and the IRS's recent Compliance Campaign, has led to chaos. This presentation chronicles the major events over the years, the key tax authorities, and the current Tax Court cases addressing the limited partner exception.
This course is part of the 2023 Tennessee Federal Tax Conference Bundle. Purchase the conference bundle here.
Credits
| Number of Credits | Type of Credits |
|---|---|
| 1.00 | Taxes |
Prices
- Member (Early Bird)
- $49.00
- Non-Member (Early Bird)
- $79.00
- Member
- $49.00
- Non-Member
- $79.00
Instructors
Hale E. Sheppard, JD, LLM
Hale E. Sheppard is a Shareholder in the Tax Dispute Section and Chair of the International Tax Section of Chamberlain Hrdlicka. He defends individual and businesses with IRS problems, particularly those involving international issues.
Hale holds five college degrees. At the University of Kansas, he earned a B.S., with distinction, M.A., with honors, and J.D. He later received an LL.M. degree in international law, with highest distinction, from the University of Chile. Finally, he obtained an LL.M. degree in tax from the University of Florida, where he was a graduate tax scholar. During his studies, Hale served as a graduate editor of the Florida Tax Review and member of the Kansas Journal of Law & Public Policy.
Hale ranks among the most active tax writers in the country, publishing over 150 major articles in some of the nation's top law reviews and tax journals, including Journal of Taxation, International Tax Journal, The Tax Adviser, Journal of International Taxation, Journal of Tax Practice and Procedure, Taxes Magazine, Practical Tax Lawyer, Journal of Passthrough Entities, Tax Management International Journal, Journal of Multi-State Tax & Incentives, Tax Notes International, Practical Tax Strategies, Journal of Real Estate Taxation, Journal of Taxation of Financial Products, and Corporate Business Taxation.
Hale has participated in over 120 cases before the U.S. Tax Court, with recent rulings including Landow v. Commissioner, T.C. Memo 2011-177 (Tax Court case regarding employee stock ownership plans and taxpayer rights in cases of involuntary conversations), Virginia Historic Tax Credit Fund v. Commissioner, T.C. Memo 2009-295, rev'd 639 F.3d 129 (case of first impression regarding federal tax treatment of state tax-credit partnerships), Topping v. Commissioner, T.C. Memo 2007-92 (hobby loss case in which the Tax Court ruled in favor of the taxpayer on all major issues), Vines v. Commissioner, 126 T.C. 279 (case of first impression involving use of mark-to-market accounting by securities traders).
Hale has also obtained over 20 favorable Private Letter Rulings for clients from the IRS National Office on assorted procedural, tax, and international issues.
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