Team Member Profile
Fifth Circuit Rejects Tax Court’s “Functional Analysis” Test in Sirius Solutions
On Friday, January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit issued a landmark decision that fundamentally disrupts the IRS’s recent campaign to limit the § 1402(a)(13) self-employment tax exception. In Sirius Solutions L.L.L.P. v. Commissioner, No. 24-60240, slip op. (5th Cir. Jan. 16, 2026), the Fifth Circuit vacated the Tax Court’s ruling …
Continue reading "Fifth Circuit Rejects Tax Court’s “Functional Analysis” Test in Sirius Solutions"