The IRS Releases CCA 201606027

By and on March 23, 2016

On February 5, 2016, the IRS released Chief Counsel Advice 201606027 (the 2016 CCA) in which the IRS concluded, among other things, that guarantees by a partner of a partnership’s liabilities that could only be called by the partnership’s lenders in certain narrow circumstances (commonly referred to as “nonrecourse carve-outs” or “bad boy” guarantees), caused the guaranteed liabilities to be treated as “recourse liabilities” allocable solely to the guarantor partner under Treasury Regulation § 1.752-2

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Levi N. Kahn
Levi Kahn focuses his practice on federal income tax matters with particular emphasis on structuring mergers and acquisitions. Read Levi Kahn's full bio.

Patrick J. McCurry
Patrick J. McCurry concentrates his practice on the corporate and tax aspects of complex business and investment transactions, with a particular focus on private equity funds, emerging businesses, partnerships and strategic joint ventures, limited liability companies and closely held corporations. He also has extensive experience in tax planning for high-net-worth individuals and families, and tax controversy matters. Read Patrick McCurry's full bio.




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