Fifth Circuit Pushes Back On IRS Attempt To Redefine Limited Partner

In Sirius Solutions, the court rejected a participation-based test for self-employment tax, finding that limited liability, ...
JD Supra

Fifth Circuit Rejects IRS’ ‘Passive Investor’ Test for Limited Partner Exception in Self-Employment Tax

On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit decisively rejected the IRS’ attempt to narrow the definition of ...
JD Supra

Fifth Circuit Rejects Government's "Passive Investor" Test for Limited Partner Exception

The U.S. Court of Appeals for the Fifth Circuit issued a pivotal decision in Sirius Solutions, L.L.L.P. v. Commissioner on January 16, 2026, ...