Raj Tanden

Dec 4, 2023 | mondaq.com | Raj Tanden

On November 28, 2023, the Tax Court ruled in Soroban Capital Partners, L.P. v. Commissioner1 that limited partners in a New York hedge fund could be subject to self-employment tax on their distributive share of partnership net income if they are actively involved, notwithstanding the Section 1402(a)(13)2 "limited partner" exception.

Nov 30, 2023 | natlawreview.com | Raj Tanden

On November 28, 2023, the Tax Court ruled in Soroban Capital Partners, L.P. v. Commissioner[1] that limited partners in a New York hedge fund could be subject to self-employment tax on their distributive share of partnership net income if they are actively involved, notwithstanding the Section 1402(a)(13)[2] “limited partner” exception.

Nov 23, 2023 | natlawreview.com | Raj Tanden

In a widely anticipated opinion,[1] on November 15, 2023 the U.S. Tax Court ruled that a fund was engaged in a U.S. trade or business through the activities of its investment manager, and that the fund was also a “dealer in securities” subject to the mark-to-market accounting rules of Section 475.[2] Because the facts of the case are unusual, we do not anticipate that the opinion should materially impact current market practices of most private funds, including credit funds.

Sep 8, 2023 | jdsupra.com | Christopher Bird |Raj Tanden

On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management (“Point72”) filed a petition with the Tax Court contesting the IRS’s position that its owner, billionaire and New York Mets team owner Steve Cohen, cannot claim the “limited partner” exception to exclude US$344 million in partnership income from self-employment tax.1 Point72 is not alone.

Sep 8, 2023 | mondaq.com | Raj Tanden |Christopher Bird

On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management ("Point72") filed a petition with the Tax Court contesting the IRS's position that its owner, billionaire and New York Mets team owner Steve Cohen, cannot claim the "limited partner" exception to exclude US$344 million in partnership income from self-employment tax.1 Point72 is not alone.