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#business-structure

Business Structure

Choose and optimize your business entity for tax and legal advantages

Employee Ownership Trusts: The Succession Planning Alternative Between Selling to a Stranger and Doing Nothing

An Employee Ownership Trust (EOT) lets a business owner sell to a permanent employee-benefit trust instead of a competitor or private equity firm, costing roughly $30,000-$100,000 to set up versus $150,000+ for an ESOP, though the U.S. still offers no federal tax incentive for EOT sales while Canada made its C$10 million capital gains exemption permanent in June 2026.

Section 1402(a)(13) After Soroban: The Limited Partner SE Tax Exemption in 2026

Since the Tax Court's 2023 Soroban decision, a state-law limited partner label no longer shields distributive share from 15.3% self-employment tax. This guide walks through the functional test under Section 1402(a)(13), the Renkemeyer line of cases, the 2024 proposed regulations, and the planning moves that still hold up for fund managers, LLC members, and operating partners in 2026.