Walter McCabe

Walter McCabe

Ropes & Gray LLP

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Update: New IRS Memo on Bad Boy Guarantees

Prior Alert. The March 17 Alert noted that the IRS in a Chief Counsel Advice ("CCA") had discussed the effect that certain “bad boy carve-out guarantees” (that would trigger contingent guarantee obligations if, for example,...more

5/10/2016 - Bad Boy Liability Carve Out Provisions Guarantors IRS Non-Recourse Loans

IRS Memo on Bad Boy Guarantees May Recharacterize Non-Recourse Debt as Recourse Liability

On February 5, 2016, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) released a memorandum (a “Memo”) related to the appropriate tax treatment of individuals or entities that invest in real estate limited...more

3/18/2016 - IRS Limited Liability Companies Limited Partnerships Non-Recourse Loans Personal Guaranties

Supreme Court's Ruling in Koontz Extends Concept of Unconstitutional Takings to Monetary Exactions

Introduction - At first glance, the Supreme Court’s recent decision in Coy A. Koontz, Jr. v. St. Johns River Water Management District, 570 U.S. ___ (2013), improves the ability of real estate developers to obtain...more

8/21/2013 - Entitlements Koontz v St John's River Water Management Land Developers Mitigation Nollan v California Coastal Commission Permits Takings

When “Loan to Own” Becomes “Own a Loan” – How a Recent Fifth Circuit Decision Rejecting the Artificial Impairment Doctrine...

Chapter 11 of the U.S. Bankruptcy Code provides debtors with a number of tools to restructure comprehensively their debts and other liabilities as well as immediate protection from secured and unsecured creditors. In single...more

3/8/2013 - Artificial Impairment Chapter 11 Cramdown Foreclosure Loans

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