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Searching Content indexed under Tax by Walter McCabe III ordered by Published Date Descending.
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Update: New IRS Memo On Bad Boy Guarantees
The CCA stated that bad boy carve-out guarantees could cause debt that purported to be non-recourse to be characterized as recourse for purposes of section 752 of the Code...
United States
16 May 2016
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IRS Memo On Bad Boy Guarantees May Recharacterize Non-Recourse Debt As Recourse Liability
The Memo does not represent established law and on its face states that it may not "be used or cited as precedent."
United States
22 Mar 2016
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