We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 1,396

Good News on “Bad Boy” Guarantees - IRS Reverts to Prior Position in Recent Legal Advice Memorandum
  • Mintz Levin Cohn Ferris Glovsky and Popeo PC
  • USA
  • May 12 2016

On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the "April GLAM") addressing the impact of so-called "bad boy"


New IRS Memo on Bad Boy Guarantees
  • Ropes & Gray LLP
  • USA
  • May 9 2016

The March 17 Alert noted that the IRS in a Chief Counsel Advice ("CCA") had discussed the effect that certain “bad boy carve-out guarantees” (that


New Tax Litigation Troubles For Liquidating Trustees
  • Steptoe & Johnson LLP
  • USA
  • May 5 2016

A core principle of bankruptcy tax litigation holds that “bankruptcy courts have universally recognized their jurisdiction to consider tax issues


SALT Implications of Proposed Section 385 DebtEquity Regulations
  • McDermott Will & Emery
  • USA
  • May 18 2016

On April 4, 2016, without warning, the US Department of the Treasury proposed a new set of comprehensive regulations under section 385. There had


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


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


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


Were the Energy Future Holdings and Caesars Chapter 11 Cases Just Saved by K Street Lobbyists?
  • Kelley Drye & Warren LLP
  • USA
  • December 29 2015

Bankruptcy and restructuring professionals usually do not need to be political junkies. Amendments to the Bankruptcy Code, and the accompanying


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