Levi N. Kahn
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Levi Kahn focuses his practice on federal income tax matters with particular emphasis on structuring mergers and acquisitions. Read Levi Kahn's full bio.
The IRS Releases CCA 201606027
By Levi N. Kahn and Patrick J. McCurry on Mar 23, 2016
Posted In IRS Guidance, Uncategorized
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...