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LLC PRINCIPAL AT-RISK AMOUNTS FOR GUARANTEED DEBT.

Authors :
BURNETT, SHARON
PULLIAM, DARLENE
Source :
Real Estate Taxation; 2016 2nd Quarter, Vol. 43 Issue 3, p127-130, 4p
Publication Year :
2016

Abstract

The article reports that Chief Counsel of the U.S. Internal Revenue Service (IRS) issued a Legal Advice Memorandum addressing the tax consequences of personal guarantees made by limited liability company (LLC) members for LLC debt. It mentions that the section 465(a)(1) U.S. U.S. Internal Revenue Code (IRC) allows individual taxpayers to recognize losses for trade or business or production of income activities and two issues concerning the at-risk rules.

Details

Language :
English
ISSN :
00935107
Volume :
43
Issue :
3
Database :
Supplemental Index
Journal :
Real Estate Taxation
Publication Type :
Periodical
Accession number :
117301262