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The Tax Court recently held in a memorandum opinion, ES NPA Holding, LLC v. Commissioner, that partnership interests in an upper-tier partnership issued to a service provider of a lower-tier partnership qualified as nontaxable profits interests.
The Tax Court recently held in a memorandum opinion, ES NPA Holding, LLC v. Commissioner, that partnership interests in an upper-tier partnership issued to a service provider of a.
On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer's receipt of interests in a partnership in exchange for services.
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.