PETER SASS

ASSOCIATE

Peter Sass advises clients on federal and international tax matters.

Practices

Education

Villanova University School of Law (LL.M. in Taxation, 2019)

Villanova University School of Law (J.D., 2014)

Rutgers University (B.S., 2011)

Bar Admissions

2015, New Jersey

2014, Pennsylvania

Insights

Limited Partner Exception to Self-Employment Tax – What to Do in Light of the Recent Soroban Case

January 10, 2024

Background on the Limited Partner Exception  Section 1401 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”), imposes self-employment tax on an individual’s self-employment income. Self-employment income is generally defined as the net earnings from self-employment, which is “the gross income derived by an individual from any trade or business carried on by…

Tax Issues and Planning to Consider Before and After Year-End 2023

December 21, 2023

This newsletter briefly highlights certain tax issues and planning that fund managers and high-net-worth individuals should consider (or reconsider) before and shortly after the end of 2023. There does not appear to be any proposed tax legislation that is expected to be enacted in the near-term, but that is always subject to change. There have…

New York PTET Elections and Other Imminent Tax Deadlines

March 9, 2023

New York Pass-Through Entity Tax (“PTET”) Due Date for Elections The due date to make elections to pay the New York State and New York City PTET for 2023 is March 15, 2023. March 15, 2023, is also the due date to elect to pay the New York City PTET for 2022, but such election…

September 15, 2022, Deadline For The New York State Pass-Through Entity Tax Election for 2022 AND New York City Pass-Through Entity Tax Can Now Apply to 2022

September 1, 2022

2022 New York State Pass-Through Entity Election Deadline The original deadline to make the New York State pass-through entity tax (“NYS PTET”) election for 2022 was March 15, 2022, but in May was extended to September 15, 2022. (Please click here for our May 2022 alert on the extension of the NYS PTET deadline.) An…

Tax Planning for Losses for Hedge Funds and Individuals

June 27, 2022

The stock and crypto markets are both significantly down from the beginning of 2022. Funds and other investors may have considerable realized and unrealized losses. Tax planning may help soften the economic impact. In this alert, we focus on tax planning for funds and individuals. The type of tax planning that may be available depends…

New York State Budget Enacts an Elective NYC Pass-Through Entity Tax

April 20, 2022

On April 9, 2022, Governor Hochul signed legislation which creates an elective NYC Pass-Through Entity Tax (the “NYC PTET”) that is very similar to the New York State Pass-Through Entity Tax (the “NYS PTET”). The NYC PTET allows certain partnerships and S corporations to elect to pay an entity level tax at a rate of…

Reminder: New York State Pass-Through Entity Tax

February 17, 2022

This newsletter serves as a reminder regarding several deadlines and action items regarding the New York State Pass-Through Entity Tax (the “NYS PTET”). March 15, 2022, Deadline The deadline to elect into the NYS PTET for 2022 is March 15, 2022. The election is made on an annual basis, so an election for 2022 will…

Certain Fund Managers May Be Required To File TIC Form SHC By March 4, 2022

February 11, 2022

Fund managers may be required to file Treasury International Capital (“TIC”) Form SHC, Report of U.S. Ownership of Foreign Securities, Including Selected Money Market Instruments (“Form SHC”), for 2021 by March 4, 2022, based on the fair value of foreign assets owned by U.S. persons determined as of December 31, 2021. For 2021 and other benchmark…

Post Year-End Tax Issues and Planning to Consider

January 10, 2022

This tax alert briefly highlights certain tax issues and planning that hedge and private equity fund managers and high-net-worth individuals should consider (or reconsider) now that we are in the new year. Our 2021 year-end tax alert highlighted many items to consider and potential tax moves to take before year-end and highlighted proposed tax changes.…