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Results: 1-10 of 1,370

Another Reason to be Cautious about “Bad Boy Non-Recourse Carve-out Guarantees”
  • Locke Lord LLP
  • USA
  • April 25 2016

On February 5, 2016 the IRS released Chief Counsel Advice Memorandum Number 201606027 (the IRS Memo) concluding that "bad boy guarantees" may cause


Update on “Bad Boy” Guarantees
  • Dickinson Wright PLLC
  • USA
  • April 22 2016

The IRS issued a Memorandum on April 15, 2016 clarifying the treatment of nonrecourse debt subject to certain “bad boy” guarantees. The Memorandum


EuroResourceDeals and Debt - April 2016
  • Jones Day
  • France, Italy, USA
  • April 21 2016

In In re Berau Capital Resources Pte Ltd, 540 B.R. 80 (Bankr. S.D.N.Y. 2015), the US Bankruptcy Court for the Southern District of New York recently


“Bad Boy Guarantee” of Non-Recourse Partnership Debt
  • Sullivan & Cromwell LLP
  • USA
  • April 18 2016

On April 15, 2016, the IRS released a generic legal Advice Memorandum (the “GLAM”) providing an important and helpful clarification of the treatment


Related-Party Debt Equity Regulations
  • Sullivan & Cromwell LLP
  • USA
  • April 14 2016

On April 4, 2016, the IRS and Treasury Department issued proposed regulations (the “Proposed Regulations”) that wouldif finalized in their current


Reorganization plan qualifies for bankruptcy exception to NOL limitation rules
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an


Escaping taxes in bankruptcy through S corporations
  • Greenberg Glusker Fields Claman & Machtinger LLP
  • USA
  • September 29 2014

Shareholders of financially troubled S corporations may now be able to avoid the flow-through of taxes when the S corporation or its subsidiary files


The Bitcoin Identity Crisis: Currency or Property?
  • Baker & Hostetler LLP
  • USA
  • February 17 2016

The confusion over Bitcoin grows in the latest lawsuit brought in a California bankruptcy court by Trustee Mark Kasolas against Marc Lowe, a former


Lenders should consider suggesting bankruptcy to borrowers following the sale of delinquent taxes on a principal residence
  • Dykema Gossett PLLC
  • USA
  • January 31 2014

The Seventh Circuit Court of Appeals recently held that a plan under chapter 13 of the Bankruptcy Code can modify the rights of a purchaser of


IRS Memo on Bad Boy Guarantees May Recharacterize Non-Recourse Debt as Recourse Liability
  • Ropes & Gray LLP
  • USA
  • March 17 2016

On February 5, 2016, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) released a memorandum (a “Memo”) related to the appropriate