Part 1 – Celsius Bankruptcy
USA, Insolvency & Restructuring, Litigation, Sullivan & Worcester LLP, Bankruptcy, Bitcoin, Cryptocurrency, Non-fungible tokens, Uniform Commercial Code (USA)
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.