LLC PRINCIPAL AT-RISK AMOUNTS FOR GUARANTEED DEBT

According to the CCA, the debt guarantor may be at risk for Section 465 purposes if the guarantee is bona fide and enforceable by the creditor under local law and the guarantor is not protected against loss by a type of arrangement listed in Section 465(b)(4). According to the CCA, when other person...

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Bibliographic Details
Published inReal Estate Taxation Vol. 43; no. 3; p. 127
Main Authors Burnett, Sharon, Pulliam, Darlene
Format Trade Publication Article
LanguageEnglish
Published New York Thomson Reuters (Tax & Accounting) Inc 01.04.2016
Subjects
Agreements
Disregarded entities
General partners
Guarantees
Internal Revenue Code
Liability
Limited liability companies
Nonrecourse debt
Property taxes
Regulation
Reimbursement
State court decisions
Subrogation
Tax deductions
Taxpayers
United States > US
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Summary:According to the CCA, the debt guarantor may be at risk for Section 465 purposes if the guarantee is bona fide and enforceable by the creditor under local law and the guarantor is not protected against loss by a type of arrangement listed in Section 465(b)(4). According to the CCA, when other persons co-guarantee an LLC's debt, a guarantor is not at risk except to the extent that the guarantor has no rights of contribution or reimbursement against the other guarantors under local law.
ISSN:1538-3792