Patrick J. McCurry
Subscribe to Patrick J. McCurry's PostsPatrick 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.
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...
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