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Tax Court Dispenses Favorable Guidance on Profits Interest Safe Harbor | Kramer Levin Naftalis & Frankel LLP

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...

Delaware , United-states , Landy , Lower-tier-partnership , Development-solutions , Upper-tier-partnership-class , Lower-tier-partnership-class , National-performance-agency , Upper-tier-partnership , Kramer-levin-naftalis-frankel , Tax-court , Npa-inc

Tax Court Provides Helpful Guidance On Requirements For Tax-Free Profits Interests - Tax Authorities

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...

United-states , Development-solutions , Tax-court , Npa-inc , United-states-tax-court , Tier-partnership , Eighth-circuit , Integrated-development-solutions , Lower-tier-partnership , Revenue-procedure , Lower-tier-partnerships

Tax Cour Tax Free Treatment under Partnership IRS Procedure

ES NPA Holding v. Commissioner T.C. Memo United States Tax Court profits interest provision of services to or for the benefit of a partnership in a partnership capacity or in anticipation of being a partner sax safe harbor services must be provided to or for benefit of partnership

United-states , Tax-court , United-states-tax-court , Tier-partnership , Npa-inc , Development-solutions , Eighth-circuit , Integrated-development-solutions , Lower-tier-partnership , Revenue-procedure , Lower-tier-partnerships

Tax Court Provides Helpful Guidance on Requirements for Tax-Free Profits Interests | Proskauer - Tax Talks

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...

United-states , Tier-partnership , Tax-court , Npa-inc , United-states-tax-court , Development-solutions , Eighth-circuit , Integrated-development-solutions , Lower-tier-partnership , Revenue-procedure , Lower-tier-partnerships

Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure | Shearman & Sterling LLP

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...

Joshus-landy , Tax-court , Development-solutions , Shearman-sterling , Npa-inc , Us-internal-revenue-service , Emerald-crest-capital , Integrated-development-solutions , Tiered-partnership , Revenue-service , Revenue-procedure ,

Climate talks need to transform into inclusive climate action for women and girls

Climate talks need to transform into inclusive climate action for women and girls
iol.co.za - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from iol.co.za Daily Mail and Mail on Sunday newspapers.

Cape-town , Western-cape , South-africa , Kwazulu , Eastern-cape , South-african , Natal , Mikateko-sithole , Mandy-barnett , Katherine-vincent , Kulima-integrated-development-solutions , Department-of-women

Merlino's domain lands in Lib territory


Merlino’s domain lands in Lib territory
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You can’t be too careful in this day and age of cyber hack attacks, as, ahem, this news organisation can attest. Internet nasties can bugger up everything.
And so to acting Premier
James Merlino, who has quite a lot on his plate since he took the top job in an acting capacity after Premier
Dan Andrews damaged his ribs and spine in his early morning Mornington Peninsula holiday home tumble.
So it is understandable that the member for Monbulk might have let things slip in the dull but important area of internet domain names.

Corio-bay , Queensland , Australia , Paris , France-general , France , Austin-park , New-south-wales , French , Michael-tozer , Norton-rose , Herbert-smith-freehills

Merlino's domain lands in Lib territory

Merlino's domain lands in Lib territory
brisbanetimes.com.au - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from brisbanetimes.com.au Daily Mail and Mail on Sunday newspapers.

Corio-bay , Queensland , Australia , Paris , France-general- , France , Austin-park , New-south-wales , French , Michael-tozer , Norton-rose , Herbert-smith-freehills

Hey Geelong, Paris called and wants its Ritz back


Hey Geelong, Paris called and wants its Ritz back
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There’s great excitement about Monday’s planned opening of the Geelong Ritz Hotel, which breathless local coverage has described as transforming “Geelong’s ugly duckling … into a magnificent swan”.
Is Geelong the new Paris of the south?
Credit:Shakespeare
In fact, the excitement is so great it has travelled 17,000 kilometres across the globe to Paris and that city’s famed Ritz Paris Hotel – “where French art de vivre meets the elegance of Belle Époque” – is none too happy.

Australia , Paris , France-general , France , United-kingdom , Copenhagen , Køavn , Denmark , Sydney , New-south-wales , China , Mansfield

CBD Sydney: CBRE propery giant's Justin Brown can't get Balmoral renovation out of the ground

CBD Sydney: CBRE propery giant's Justin Brown can't get Balmoral renovation out of the ground
smh.com.au - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from smh.com.au Daily Mail and Mail on Sunday newspapers.

Australia , Perth , Western-australia , Balmoral , New-south-wales , Paris , France-general , France , Sydney-heads , Queensland , Canberra , Australian-capital-territory