On January 16, 2026, in Sirius Solutions, L.L.L.P. v. Commissioner,[1] No. 24-60240 (5th Cir. Jan. 16, 2026), the U.S. Court of Appeals for the Fifth Circuit reversed the Tax Court and held that, for self-employment tax purposes, a “limited partner” means “a partner in a limited partnership that
Laura Gavioli
How Relevant Is It? The Economic Substance Doctrine According to Liberty Global and Patel
I. Introduction
Should courts respect a transaction for tax purposes, when it otherwise complies with the technical requirements of the Internal Revenue Code and regulations? When should a court take the next step and consider the economic substance of a transaction and its motivations?
In two highly-awaited court decisions…
Unsuccessful Taxpayer Change in Domicile from New York to Florida Shows that Courts will Follow the Money
By Laura Gavioli & Lylah Paine on
Snowbirds, take notice. In October 2025, the New York State Tax Appeals Tribunal issued a decision regarding a couple’s claimed change in domicile from New York to Florida for the 2018 and 2019 tax years. Matter of Hoff and Ocorr-Hoff, DTA No. 850209 (N.Y.S. Tax Appeals Trib. Oct. 9, 2025)…