News & Analysis as of

Income Taxes › Debt Instruments

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Mayer Brown

Exploring the Unexpected and Often Unwelcome Federal Income Tax Consequences of Debt Modifications

Mayer Brown on

As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more

Hogan Lovells

With a New Year, Brings a New Rate . . . The Transition from LIBOR Is Now Here

Hogan Lovells on

In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more

Miller Nash LLP

Today in Tax: Financial Contract Modification and Foreign Tax Credits

Miller Nash LLP on

Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued interbank offered rate (“IBOR”) will need to transition to an...more

Mayer Brown Free Writings + Perspectives

Modification of Intra-Group Debt Instruments

Mayer Brown Free Writings + Perspectives on

Background. Just as with debt instruments between unrelated parties, the current economic downturn may cause related parties to want to modify the terms of debt instruments existing between them. ...more

Snell & Wilmer

Look Before You Lend: A Practical Discussion of Tax Issues to Consider When Lending to an Emerging Business

Snell & Wilmer on

Private credit appears to be the dominating trend throughout emerging business markets. Businesses seeking to raise capital are finding private investors who, unsurprisingly, are looking to maximize yield, while at the same...more

A&O Shearman

Section 385 Treasury Regulations Developments

A&O Shearman on

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Foley & Lardner LLP

IRS Proposed Regulations Provide Flexibility for LIBOR Phase-out

Foley & Lardner LLP on

On October 9, 2019, the United States Treasury Department published proposed regulations that address the federal tax consequences of the expected phase-out of the London interbank offered rate (LIBOR) after 2021 and possible...more

Sherman & Howard L.L.C.

Treasury Releases Proposed LIBOR Replacement Regulations

Sherman & Howard L.L.C. on

On October 8, 2019, the United States Department of the Treasury released proposed regulations (the “Proposed Regulations”) specifying how an amendment to a debt instrument or non-debt contract (e.g., a swap) to replace the...more

Kramer Levin Naftalis & Frankel LLP

Proposed Regulations Mitigate Tax Issues Lurking in LIBOR-Referencing Debt Instruments and Other Contracts

Kramer Levin Naftalis & Frankel LLP on

On Oct. 9, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (the Proposed Regulations) providing taxpayers with broad and flexible guidance on the tax...more

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

Proskauer - Tax Talks on

The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the...more

Eversheds Sutherland (US) LLP

Relief for REMICs addressing phaseout of LIBOR

Eversheds Sutherland (US) LLP on

New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, the...more

A&O Shearman

Treasury and the IRS Release Tax Guidance on the Transition from Interbank Offered Rates

A&O Shearman on

On October 8, 2019, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a pre-published version of proposed regulations addressing the principal tax consequences related to the...more

A&O Shearman

Tax Guidance on the Transition From Interbank Offered Rates Under OIRA Review

A&O Shearman on

On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the “Proposed Regulations”) to the Office of Management...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

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