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QUESTIONS & ANSWERS

Emerging Issues and Insights

Q. Is a limited partner always subject to the §1411 net investment income tax if the partner is receiving an allocation of partnership income that is reported as not subject to self-employment tax by reason of being a limited partner?

A.

No. If the limited partner is a material participant in the business under §469 standards, the income can avoid both the SE tax and the NII tax. In fact, if the partner provides the services through a management company, the result does not change. (See Reg. §1.469-5(f) and Reg. §1.469-5T(k) Ex. 2, both of which provide that services provided for a partnership in any capacity count for §469 material participation purposes.)

None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.

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