Sirius and SECA: What Changes, What Doesn't, and What Comes Next

The Fifth Circuit’s decision in Sirius marks the first appellate rejection of the Tax Court’s functional approach to the limited partner exception, instead focusing on state law status, statutory text, and longstanding tax administration principles. While binding only in the Fifth Circuit, the decision provides an important new reference point for evaluating and managing SECA exposure.

EisnerAmper and Morgan Lewis invite you to a practical discussion of what Sirius changes—and what it does not. Partner and Tax Controversy Leader, Miri Forster, will join Morgan Lewis attorneys to examine implications for audit posture, appeals strategy, filing positions, and forward‑looking structuring, with particular emphasis on governance discipline and preserving state‑law limited liability.

The program will also address jurisdictional considerations, including how Sirius may affect pending matters in the First and Second Circuits and how taxpayers should position themselves in an evolving but unsettled landscape.

CLE Credit: CLE credit is pending approval in CA, FL, IL, MN, NY*, OH, OR, PA, TX, VA, and WA. Credit in CT and NJ is pending via reciprocity. CLE credit is not available for recorded sessions.
*Qualifies for Newly Admitted Attorneys.