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Current Federal Tax Developments · Jan 16, 2026

Fifth Circuit Vacates Tax Court in Sirius Solutions: A Return to Statutory Text for Section 1402(a)(13)

Tax Brief summary and classification of the original reporting.

Bottom Line

💡 Fifth Circuit Vacates Tax Court in Sirius Solutions: A Return to Statutory Te.... Worth reviewing for potential client impact.

Summary

The United States Court of Appeals for the Fifth Circuit has delivered a significant decision regarding self-employment (SE) tax liability for limited partners, overturning the Tax Court’s reliance on the "functional analysis" test established in Soroban Capital Partners LP v. Commissioner. In Si...

Classification

Category: fyiPriority: importantReason: Contains 'tax court' - significant update

Applies To

1065payroll

Affected Groups

Partnership/LLC preparers, Payroll/employment tax specialists

Original Source

We aggregate public tax updates and provide AI-assisted summaries. Please read the original reporting for full details.

Read original article