Do you have any Cayman vehicles that you are considering terminating?
Cayman Islands, Capital Markets, Insolvency & Restructuring, Private Client & Offshore Services, Ogier, Liquidation
Do you have Cayman vehicles that you are considering terminating?
If so, you should consider initiating the process now to minimise or eliminate 2020 annual fees. This note contemplates corporate vehicles but similar considerations apply to partnerships.
Termination by voluntary liquidation
Cayman Islands, Insolvency & Restructuring, Private Client & Offshore Services, Securitization & Structured Finance, Ogier, Cayman Islands Monetary Authority
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.