The Fifth Circuit says this is Sirius business: The IRS loses its fight against the limited partner exception to Self-Employment Contributions Act (SECA)

Upsetting a string of wins for the Internal Revenue Service ("IRS") in the Tax Court, the Fifth Circuit recently rejected the "functional analysis" test for determining whether a limited partner's partnership income is subject to tax under the Self-Employment Contributions Act ("SECA"). Instead, the Fifth Circuit concluded that the key question is whether the partner is entitled to limited liability under state law.... By: White & Case LLP