United States: Tax Court Agrees Profits Interest Safe Harbor Should Apply To Tiered Partnership Structure - Shearman & Sterling LLP

United States: Tax Court Agrees Profits Interest Safe Harbor Should Apply To Tiered Partnership Structure - Shearman & Sterling LLP

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On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner[1] holding that the taxpayer's indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...

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