TaxationEzra Dyckman and Daniel W. Stahl, New York Law Journal
New Regulations Disregard Partnership 'Bottom Guarantees'
In their Taxation column, Ezra Dyckman and Daniel W. Stahl write that partners have long enjoyed the ability to influence a partnership's allocation of its liabilities by making a "bottom guarantee" of partnership debt, and conclude: "We have known that the end was coming for bottom guarantees since the issuance of proposed regulations by the Treasury Department in 2014. That expectation has now become a reality, as temporary regulations regarding bottom guarantees were issued earlier this month."
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