Kissing the Blarney Stone — A Practical Guide to Structuring Partnership Agreements and Limited Liability Company Operating Agreements in Light of the § 1446 Regulations

47 Tax Management Memorandum 171 (2006)

15 Pages Posted: 10 Jul 2015

Date Written: May 1, 2006

Abstract

Until the advent of § 1446, 1446's main claim to fame may have been that it was the year that Blarney Castle in its current incarnation was built in Cork, Ireland. There seems to be a mystical connection here. Certainly, the interminable § 1446 regulations, and especially the ponderous temporary regulations in Regs. § 1.1446-6T, lead one to believe that the drafters had visited the castle, more than once, where the Blarney Stone is said to confer the gift of the gab on those who kiss it (while hanging backward off a parapet).

Suggested Citation

Karlin, Michael J.A. and Appel, Alan, Kissing the Blarney Stone — A Practical Guide to Structuring Partnership Agreements and Limited Liability Company Operating Agreements in Light of the § 1446 Regulations (May 1, 2006). 47 Tax Management Memorandum 171 (2006), Available at SSRN: https://ssrn.com/abstract=2628205

Michael J.A. Karlin

Karlin & Co.

50 South Rodeo Drive, Suite 220
Beverly Hills, CA 90212
United States
310-274-5275 (Phone)
310-388-5537 (Fax)

Alan Appel (Contact Author)

New York Law School ( email )

185 West Broadway
New York, NY 10013
United States

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