We found a match
Your institution may have rights to this item. Sign in to continue.
- Title
Real Estate & Passthrough Corner.
- Authors
Masterson, Brian S.; Lencz, Norman
- Abstract
The article focuses on the Chief Counsel Advice (CCA) 201308028 provided by the Internal Revenue Services (IRS) Office of the Chief Counsel in the U.S. It states that the CCA is for the clarification on the proposed Code Section Reg. §1.465-6(d) which does not guarantee to a member of a limited liability company (LLC) of entity-level debt. It also mentions that the CCA guidance is helpful for LLC that does not constitute qualified nonrecourse financing with nonrecourse debt.
- Subjects
UNITED States; UNITED States. Internal Revenue Service. Office of the Chief Counsel; PRIVATE companies; CORPORATE debt financing; DEBT management; NONRECOURSE debt
- Publication
Journal of Passthrough Entities, 2013, Vol 16, Issue 5, p33
- ISSN
1099-7407
- Publication type
Article