LLC PRINCIPAL AT-RISK AMOUNTS FOR GUARANTEED DEBT

• Published in: Real Estate Taxation Vol. 43; no. 3; p. 127
• Main Authors: Burnett, Sharon, Pulliam, Darlene
• Format: Trade Publication Article
• Language: English
• 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

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...