The IRS recently released Revenue Procedure 2020-44 (“Rev. Proc. 2020-44”) which provides helpful relief to taxpayers by providing that if a contract referencing an IBOR is modified to incorporate specific ISDA or AARC fallback language for the replacement of IBORs, such modification will not cause certain adverse tax consequences, such as exchange treatment under Section 1001 of the Tax Code, or the legging out or termination of integrated transactions under Treasury Regulation Sections 1.1275-6, 1.988-5(c) or 1.148-4(h).
Continue Reading IRS Revenue Procedure 2020-44: Floating Rate Fallback Flexibility from the Feds

The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of the upcoming phase-out of the London Interbank Offered Rate (LIBOR) and other interbank rates (collectively, IBORs).
Continue Reading Treasury Proposes Guidance to Minimize Tax Consequences of LIBOR Phase-Out