An About-Face?

Earlier this year, the federal Court of Appeals for the Fifth Circuit^[i] ruled that the U.S. Tax Court had misinterpreted the Code’s self-employment tax rules as they apply to individuals who hold limited partnership interests in a state law limited partnership, notwithstanding that such individuals also render services to the partnership of a nature that is integral to the limited partnership’s business.^[ii]

I’m delighted to share that FeedSpot has ranked TaxSlaw 21 in its list of the 100 Best Tax Blogs to Follow in 2026.

This blog is a labor of love, and it feels good to know that my weekly efforts have gained some recognition.

Sending a special thank you to my loyal readers who…

The Long-Term View

Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole.[i]

Implicit in this approach toward tax legislation is the enactment of a set of relatively constant and long-lasting rules on which businesses[ii] may rely when planning for the future.

Under this long-term view of tax policy, a provision that is drafted to be short-lived probably should not be adopted unless Congress reasonably determines the provision will generate benefits that endure well beyond its expiration.  

Our Holiday

Thanksgiving has been a national holiday in the U.S. since 1870. During most of that period, at least until recently, it has also been a unifying force as immigrants to this country, eager to be assimilated to American society,[i] and recognizing the holiday’s universal message of gratitude,[ii] have adopted the day as their own.[iii]

In 1863, only months after the Battle of Gettysburg and the Siege of Vicksburg, and a few years before Thanksgiving officially became a national holiday, President Lincoln issued the following Proclamation:[iv]

Solace in the Mundane?  

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation, tighter credit, recession, crypto-nonsense, recreational cannabis, legalized gambling, men competing in women’s sports, a nation divided over all too many things, the Knicks down to the Heat 3 games to 2,[i] the prospect of Biden vs Trump II,[ii]. . . , the list goes on.[iii]

Taxing the Rich

During the last couple of months, as we headed into what most folks – excluding transactional attorneys – call the “Holiday Season,”[i] tax authorities from around the globe have been calling for increased taxes on the rich, however one chooses to define this class of individuals.

The chief economist for the European Central Bank, relying on macroeconomic policy and concepts of “fairness,” advised governments to tax the rich to support society’s vulnerable groups.[ii]

In the U.K., His Majesty’s Revenue & Customs announced an initiative to pursue tax fraud by the wealthy and mid-size businesses. In fact, it has been reported that HMRC plans to go so far as to assign agents to personally monitor the tax affairs of certain individuals – an odd variation on the “buddy system.”
Continue Reading Pigs Get Fed, and Pay Their Taxes, But Hogs – That Remains to be Seen