Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
Podcast - La Prima por Fusión
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
10 Things Lawyers Should Know About BVI Transactions
Tax Planning Under a Biden Presidency
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Tax Provisions in Business Acquisition Agreements
On February 5, 2016, the Internal Revenue Service (IRS) released Chief Counsel Advice 201606027 (the 2016 CCA) in which the IRS concluded, among other things, that guarantees by a partner of a partnership’s liabilities that...more
I. OVERVIEW - A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more