Tax in Action: Practical Strategies for Tax Pros

Jeremy Wells, EA, CPA

Join Jeremy Wells, EA, CPA, as he breaks down the complexities of tax law into practical guidance you can apply immediately. Each episode focuses on a specific tax strategy, credit, or compliance issue that matters to tax professionals and business owners. Rather than theoretical discussions, Jeremy delivers actionable insights based on real-world scenarios and current tax regulations. Whether you're navigating Section 1031 exchanges, maximizing research credits, or helping clients with energy tax incentives, this podcast provides the technical details and strategic considerations you need to confidently serve your clients. Perfect for tax practitioners looking to deepen their expertise and business owners wanting to make more informed tax decisions.

  1. Jul 8

    Limited Partner or Not? Why Courts Are Split on Your Tax Bill

    Jeremy digs into what actually makes someone a partner for federal tax purposes, tracing the definition back to the Supreme Court's Tower and Culbertson decisions and the "hypothetical liquidation" test for capital interests. From there, he unpacks the messier question of self-employment tax on partnership income: the undefined "limited partner as such" exception under IRC Section 1402(a)(13), and the current circuit split between the Tax Court's functional analysis (Renkemeyer, Soroban) and the Fifth Circuit's state-law approach in Sirius Solutions, with Denham Capital Management still pending at the First Circuit. SponsorsThomson Reuters - http://taxshow.promo/taxautomation (00:00) - Partnerships Recap Goals (01:27) - LLC Members Case Study (03:17) - Are Partners Equal (05:11) - Who Counts As Partner (10:14) - Tower Case Principles (14:48) - Culbertson Intent Test (17:30) - Congress Defines Capital Interest (26:26) - Capital Interest Explained (28:47) - General Versus Limited Partners (30:18) - Self Employment Tax Basics (33:19) - Limited Partner Definition Fight (36:06) - Key Court Cases Split (48:47) - New Cases Jurisdiction Issues (52:12) - Back To LLC Example (55:02) - Takeaways Next Episode Connect with Jeremyhttps://www.linkedin.com/in/jwellstaxhttps://www.steadfastbookkeeping.com Subscribe on YouTubehttps://www.youtube.com/@TaxinAction Earn CPE for Listening to This Podcasthttps://www.earmark.app/ This podcast is a production of Earmark Media

    Limited Partner or Not? Why Courts Are Split on Your Tax Bill
  2. Jun 24

    When Does Co-Ownership Become a Partnership

    Two friends sharing a short-term rental, a married couple flipping houses, siblings splitting the income from a property they own together: any of these could be a partnership for federal tax purposes, often without the owners realizing it. This episode works through how federal tax law defines a partnership, when one actually forms, and why mere co-ownership does not automatically create one, drawing on Subchapter K, the regulations, and foundational cases like Tower and Culbertson. It also separates two regimes that frequently get conflated, the qualified joint venture under Section 761 and the community property LLC exception under Revenue Procedure 2002-69, and closes with a framework for making the call. SponsorsThomson Reuters - http://taxshow.promo/taxautomation (00:00) - Rental Friends Scenario (01:36) - Why Partnership Status Matters (02:28) - Aggregate Versus Entity (04:22) - Goals For This Episode (05:51) - IRS Partnership Definition (09:12) - Mere Co Ownership Tests (14:10) - LLCs And Entity Rules (17:20) - When A Partnership Forms (23:22) - Supreme Court Guidance (27:45) - Court Factors Checklist (33:50) - Electing Out Of Subchapter K (39:41) - Spouse Exceptions Explained (49:08) - Two Step Decision Framework (54:31) - Case Study Short Term Rental (57:01) - Key Takeaways And Wrap Up Connect with Jeremyhttps://www.linkedin.com/in/jwellstaxhttps://www.steadfastbookkeeping.com Subscribe on YouTubehttps://www.youtube.com/@TaxinAction Earn CPE for Listening to This Podcasthttps://www.earmark.app/ This podcast is a production of Earmark Media

    When Does Co-Ownership Become a Partnership
4.9
out of 5
17 Ratings

About

Join Jeremy Wells, EA, CPA, as he breaks down the complexities of tax law into practical guidance you can apply immediately. Each episode focuses on a specific tax strategy, credit, or compliance issue that matters to tax professionals and business owners. Rather than theoretical discussions, Jeremy delivers actionable insights based on real-world scenarios and current tax regulations. Whether you're navigating Section 1031 exchanges, maximizing research credits, or helping clients with energy tax incentives, this podcast provides the technical details and strategic considerations you need to confidently serve your clients. Perfect for tax practitioners looking to deepen their expertise and business owners wanting to make more informed tax decisions.

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