EXECUTIVE SUMMARY
United Kingdom, Company & Commercial, Insolvency & Restructuring, K&L Gates LLP, Coronavirus, HM Revenue and Customs (UK)
Executive Summary
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.