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Story perspectives

IRS Revises Tax Rules for Private Equity Limited Partners

6/5/2025

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Story summary
  • The IRS claims limited partners in private equity and hedge funds could owe SECA tax, revising earlier exclusions.
  • Recent court cases, like Soroban Capital Partners LP v. Commissioner, question the limited partner exclusion for state-law limited partners.
  • Ongoing appeals and pending litigation indicate the matter is still unresolved, with potential Supreme Court review expected.