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In response to the Memorandum, a small task force from the Real Estate Roundtable, including Joe Forte of Kelley Drye & Warren LLP, drafted an industry position paper and met with IRS Chief Counsel William Wilkins to share the real estate community’s concerns.

In a typical real estate partnership, a partner’s tax basis and at-risk investment is derived from his equity contribution plus his share of partnership “recourse” liabilities and his share of “non-recourse” liabilities (in the case of computing tax basis) and his share of “qualified non-recourse financing” (in the case of computing at-risk investment).The IRS Office of Chief Counsel released legal memorandum 201606027 (the “IRS Memorandum” or “Memorandum”) that called into question two fundamental and well-established aspects concerning the tax treatment of investors in real estate limited partnerships and limited liability companies that utilize non-recourse financing.The Memorandum concluded that a customary “bad boy” guarantee given by an LLC member in connection with the LLC’s real estate non-recourse financing was sufficient to cause the financing (a) to constitute a “recourse” liability for purposes of determining the members’ tax basis in the LLC and (b) to fail to be a “qualified non-recourse financing” under the at-risk investment rules.Also offers Business IT & Intelligence to BPO / KPO Fluent ( acquired by ANSYS ) has been in the development of CFD software for simulating fluid flow, heat and mass transfer, and a host of related phenomena involving turbulence, reactions, and multiphase flow.Harbinger systems services are claimed to be solution consulting, software design, development, testing and test automation ; with focus and specialized skills in Web 2.0, e Learning Technology, Software Product Development and Systems Software.

“bad boy” events often include the partnership’s voluntary bankruptcy filing, the managing partner’s filing of an involuntary bankruptcy petition against the partnership, etc.

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