On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the characterization of underlying partnership debt as recourse vs. nonrecourse under Section 752 of the Internal Revenue Code.
The Land and Conveyancing Law Reform Act 2013 (“the Act”) has been enacted. The Act addresses the unintended consequences arising from the Land and Conveyancing Law Reform Act 2009 (“the 2009 Act”).
Summary