SECA Tax Saga Advances to Appellate Courts in 2026, Tax Notes

Partner Jennifer Breen was quoted in a Tax Notes article examining how pending appellate decisions could shape the future of the limited partner exception to self-employment tax under SECA.

Jennifer emphasized that while an expected Fifth Circuit decision in Sirius Solutions LLLP v. Commissioner will be influential, it is unlikely to provide a definitive resolution. “The Fifth Circuit will influence the trajectory of the limited partner exception, but it won’t end the debate,” she said, adding that broader clarity will depend on how other circuits weigh in and how the IRS and taxpayers respond.

Read the full Tax Notes article >>