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Libor Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

IRS Publishes Final Regulations on IBOR Transition for Published Rate Elections

On June 29, 2023, the IRS published final regulations that provide the appropriate reference rate to be used by a foreign bank that elects to use a published rate to determine the amount of excess interest expense allocable...more

Foley & Lardner LLP

Treasury Releases Guidance on the Transition from Interbank Offer Rates to Other Reference Rates with Respect to the Interest...

Foley & Lardner LLP on

On June 30, 2023, the United States Department of the Treasury (“Treasury”) published Final Regulations as guidance on the transition from the use of the Interbank Offer Rate (IBOR) to the Secured Overnight Financing Rate...more

ArentFox Schiff

The Long and Winding Road: The End of LIBOR

ArentFox Schiff on

USD LIBOR is the last step in the long and winding road that has been LIBOR’s slow demise over the last several years as all other LIBOR instruments worldwide have already substantially transitioned. As taxpayers prepare...more

Foster Garvey PC

2023 Reminder to Issuers and Borrowers of LIBOR-Based Tax-Exempt Bonds: Now is the Time to Protect the Tax-Exempt Status of Bonds...

Foster Garvey PC on

As we welcome 2023, and the final six months of certain London Interbank Offering Rates (“LIBOR”), issuers and borrowers of LIBOR-based tax-exempt bonds should evaluate whether changes to their financing documents are...more

Sheppard Mullin Richter & Hampton LLP

CFTC Amends Clearing Requirements

On August 12, 2022, the CFTC issued a final rule modifying its clearing requirement for interest rate swaps (“IRS”). ...more

ArentFox Schiff

Federal Law to the Rescue? (The Senate Version)

ArentFox Schiff on

LIBOR Relief Included In Appropriations Bill - New York Law Concerns - The New York law enacted in April 2021 provides the ‘Get Out of Jail’ card[2] for banks from litigation relating to the LIBOR (London InterBank...more

Dechert LLP

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered modifications,” as defined, of certain...more

Eversheds Sutherland (US) LLP

Anticipating the end: IRS finalizes LIBOR transition guidance

Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more

Mintz - Public Finance Viewpoints

Treasury and IRS Release Final Tax Regulations for LIBOR Replacement Amendments

The lengthy saga of the transition to a post-LIBOR world reached a degree of finality on the tax side with the issuance by the Department of Treasury and Internal Revenue Service (IRS) of long-awaited final regulations (the...more

A&O Shearman

Government Releases Final Tax Regulations on the Transition from Interbank Offered Rates

A&O Shearman on

On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...more

Holland & Knight LLP

IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition

Holland & Knight LLP on

The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates...more

ArentFox Schiff

Buckle Your Seatbelts: Tax Ramifications of the LIBOR Transition

ArentFox Schiff on

Although this article is focused on tax-exempt debt, the tax ramifications of the LIBOR transition are not limited to the municipal finance world, and the elimination of LIBOR may also have a significant impact on taxable...more

Adler Pollock & Sheehan P.C.

The LIBOR Phase-Out: What Borrowers Should Know Now

The London Interbank Offered Rate (“LIBOR”) is a benchmark interest rate index used in setting the interest rate for many variable-rate loans and other financial obligations. LIBOR is currently set to be phased out in...more

Cozen O'Connor

IRS’ LIBOR Fallback Guidance Provides Limited Reissuance Relief to Tax-Exempt Bond Issuers

Cozen O'Connor on

In 2017, the United Kingdom regulator overseeing the London Interbank Offered Rate (LIBOR), a benchmark for rates for short-term interbank loans, announced that all currency and term variants of LIBOR, including U.S. dollar...more

Ballard Spahr LLP

IRS Releases Guidance on the Transition From LIBOR

Ballard Spahr LLP on

The IRS recently released helpful guidance in Revenue Procedure 2020-44 to assist the market’s transition from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (IBORs) to alternative reference...more

McDermott Will & Emery

Weekly IRS Roundup October 5 – October 9, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020... October 7, 2020: The IRS published final regulations...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

Orrick, Herrington & Sutcliffe LLP

Tax Relief for Replacing LIBOR in Tax-Exempt Debt and Swaps

Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more

Holland & Knight LLP

Treasury Department, IRS Issue Proposed Rules on Tax Impact of Transition from Libor

Holland & Knight LLP on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more

Kramer Levin Naftalis & Frankel LLP

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

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

Dechert LLP

Proposed Tax Rules on LIBOR Replacements Answer Some (But Not All) Questions

Dechert LLP on

Last week, the U.S. Department of the Treasury released proposed rules providing tax guidance around various LIBOR replacement issues. Long anticipated. The defenestration of LIBOR will leave considerable broken glass in its...more

Mintz - Public Finance Viewpoints

SOFR So Good! IRS Makes It Easier to Say ‘Goodbye’ to LIBOR

Lenders, creditors and swap parties may finally begin to replace LIBOR with confidence. While LIBOR’s demise was announced in 2017, efforts to amend the vast pool of LIBOR-based bonds and swaps to reference a replacement...more

McGuireWoods LLP

Treasury Proposes Guidance to Minimize Tax Consequences of LIBOR Phase-Out

McGuireWoods LLP on

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...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

Troutman Pepper

Tax Relief May Be Ahead for Market Participants Transitioning Away From LIBOR

Troutman Pepper on

Tax relief may be coming for issuers and holders of debt instruments and parties to derivatives and other financial contracts governed by LIBOR (the London Interbank Offered Rate). ...more

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