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The View from Proskauer on Developments in the World of Employee Benefits, Executive Compensation & ERISA Litigation

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Tyler Forni

Associate
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Tyler Forni is an associate in the Tax Department and a member of the Employee Benefits & Executive Compensation Group.

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Tax Court Decision Interprets Profits Interest “Safe Harbor” under IRS Rev. Proc. 93-27

By Michael Album, Kate Napalkova, David Teigman, Nicholas LaSpina and Tyler Forni on Posted in Executive Compensation
The Tax Court’s May 3, 2023, decision in ES NPA Holding, LLC v. Commissioner (T.C. Memo 2023‑55), upholding a taxpayer’s position to characterize a partnership interest as a profits interest under the “safe harbor” of IRS Revenue Procedure 93-27 (as clarified by IRS Revenue Procedure 2001-43), provides helpful guidance to issuers of profits interests, including … Continue Reading
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