Bad Boy Guarantee Makes Loan Recourse?

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 … Continue reading Bad Boy Guarantee Makes Loan Recourse?