cintineocpa
Level 2
12-07-2019
12:11 AM
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poolcleaner
Level 9
12-07-2019
12:11 AM
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In general. limited partners do not pay self employment tax. They do pay SE on Guaranteed Payments. I would look to the partnership agreement since Sec. 301.7701-3 does not address whether an LLC making a partnership election is considered a general partnership or a limited partnership for federal income tax purposes and whether LLC members are considered general or limited partners.
poolcleaner
Level 9
12-07-2019
12:11 AM
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Before the advent of 199A the IRS would be looking to make as much as possible subject to SE tax, but logic says they may be going in the opposite direction now.
