United States: Tax Court Decision Interprets Profits Interest "Safe Harbor" Under IRS Rev. Proc. 93-27 - Proskauer Rose LLP
Published
The Tax Court's May 3, 2023, decision in ES NPA Holding, LLC v. Commissioner (T.C. Memo 2023‑55), upholding a taxpayer's position to characterize a partnership interest as a profits interest...
Full Article