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Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more

Good News on “Bad Boy” Guarantees – IRS Reverts to Prior Position in Recent Legal Advice Memorandum

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...more

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