Transmittal email forwarding a CCA memo on SECA loss limitations for a general partner

Plain-English summary

This is a short transmittal email forwarding a separate Chief Counsel Advice memorandum. The email explains that the attached CCA memo, based on the offices' earlier discussions and a general fact pattern, addresses whether the loss limitations apply in determining a general partner's self-employment (SECA) tax, and it notes that a redacted version will be published as necessary to protect privileged or confidential information. The email itself contains no legal analysis; it simply describes the subject of the attached memorandum (the interaction between the loss limitation rules, such as the at-risk rules of section 465, and the computation of net earnings from self-employment under section 1402 for a general partner).

Ruling snapshot

• Question: (Transmittal) forwarding a CCA memo on whether the loss limitations apply in determining a general partner's self-employment tax.
• Outcome: advice (cover email; the substantive analysis is in the attached memorandum)
• Key authorities: IRC §§ 1402 (net earnings from self-employment), 465 (at-risk loss limitation)

Full text (IRS public release)

ID:        CCA_2019030415405751
UILC:      1402.01-00, 465.00-00

Number: 201916005
Release Date: 4/19/2019
From:
Sent: Monday, March 04, 2019 3:40:57 PM
To:
Cc:
Bcc:
Subject: SECA-loss limitations

Hi,

Attached is a CCA memo based on our earlier discussions, including about a general
fact pattern, on the issue of whether the loss limitations apply in determining a general
partner’s self-employment tax. We will publish a redacted version (as necessary for any
privileged or confidential information).

If you have any questions or concerns, feel free to contact us.

Thank you,

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