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.
On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier.