Ezra Dyckman and Charles S. Nelson No Sweat (Equity): Tax Court Addresses Partnership Profits Interests
In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the recent case, 'ES NPA Holding, LLC v. Commissioner,' where the Tax Court interpreted Revenue Procedure 93-27 favorably. The case showed that taxpayers receiving partnership profits interests should be careful to ensure that they have satisfied all requirements of the revenue procedure.
June 27, 2023 at 11:00 AM
5 minute read
When a person contributes property to a partnership in exchange for a partnership interest, the transaction is usually not subject to federal income tax. In contrast, when a person performs services for a partnership in exchange for a capital interest in the partnership, the transaction is generally taxable.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
Law Firms Mentioned
Trending Stories
- 1The Law Firm Disrupted: For Big Law Names, Shorter is Sweeter
- 2Wine, Dine and Grind (Through the Weekend): Summer Associates Thirst For Experience in 'Real Matters'
- 3'That's Disappointing': Only 11% of MDL Appointments Went to Attorneys of Color in 2023
- 4What We Know About the Kentucky Judge Killed in His Chambers
- 5'I'm Staying Everything': Texas Bankruptcy Judge Halts Talc Trials Against J&J
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250
