By: Amanda Wilson
After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include:
By: Amanda Wilson
After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include:
By: Amanda Wilson
The IRS recently released IRS legal memorandum 201606027. In this memorandum, the IRS considered the impact of a bad boy guarantee on allocating partnership liabilities under Section 752. Traditionally, bad boy guarantees have not been viewed as resulting in a partnership liability being allocated to the guarantor, as the guarantee obligation has been viewed as subject to contingencies that make it unlikely that the guarantee would ever come into play.