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- Title
Real Estate & Passthrough Finance Techniques Corner "Bad Boy" Nonrecourse Carve-outs in Real Estate Loan Cause It to Be Recourse—or Do They?
- Authors
Rubin, Blake D.; Macintosh Whiteway, Andrea
- Abstract
The article discusses the facts analyzed and the arguments presented by practitioners in the public Chief Counsel Advice (CCA) which was released by the U.S. Internal Revenue Service (IRS) on February 5, 2016. The CCA conclusion on the nonrecourse real estate loan is noted to cause trillions of dollars of nonrecourse loans that contains bad boy nonrecourse carve-out provisions which is contrary to their position on tax return. The issuance of the Generic Legal Advice Memo is also mentioned.
- Subjects
UNITED States; UNITED States. Internal Revenue Service; GOVERNMENT policy; MORTGAGE loans; NONRECOURSE debt; TAX returns; REAL property
- Publication
Journal of Passthrough Entities, 2016, Vol 19, Issue 4, p27
- ISSN
1099-7407
- Publication type
Article