On Liquidation Tax Matters, Partner Would Not Receive Any Proceeds, Thus the Interest Received Would Be a Nontaxable Profits Interest
January 17, 2024 | Court Rulings, Valuations
ES NPA Holding, LLC v. Comm’r, T.C. Memo 2023-55 The Tax Court ruled that the Class C units were a profits interest because, applying the fair market value of the LLC at the time of receipt, the partner would not receive any proceeds from a liquidation at that time. Any proceeds in excess of fair Continue Reading »