Robinson Bradshaw

Topic: Tax

Tax Court Takes Narrow View of Limited Partner Exclusion from SECA Tax

The Tax Court, in a victory for the IRS, recently issued an opinion holding the limited partner exception to the Self-Employed Contributions Act Tax must be construed narrowly. The court held a limited partner under state law is not automatically a limited partner for purposes of the SECA exclusion. SECA Background SECA imposes a tax […]

280G Considerations for Portfolio Company Exits

Portfolio companies of venture capital and private equity funds usually motivate key executives through compensation tied to performance upon an exit. Such structures align the incentives of the fund with those of the executives but can lead to several tax issues that warrant thoughtful consideration. 280G Background Section 280G of the Internal Revenue Code seeks […]