Nickolas Gianou

May 11, 2023 | lexology.com | Nickolas Gianou |Nathan Giesselman |Kathleen Gregor |Shalom Huber |Sarah Rizzo |Paul Schockett | +2 more

On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the benefit of an operating partnership in a tiered partnership context. ES NPA Holding LLC v. Commissioner, T.C. Memo 2023-55 (May 3, 2023).