Norman Lencz and Brian Masterson (former Venable partner) published "Guarantors: Are You At Risk?" in the September-October 2013 edition of the Journal of Passthrough Entities in the “Real Estate & Passthrough Corner” column.
Recent Internal Revenue Service Private Letter Rulings Clarify Application of Sections 865(h) and 904(h)(10) Under Treaties That Defer to Domestic-Law Sourcing