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Final Treasury Regulations Published on Transition from IBORs to Qualified Rates

The Internal Revenue Service and the US Treasury Department have issued final regulations providing rules for taxpayers transitioning from interbank offered rates to qualified rates. These regulations provide financial...more

IRS Extends REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearances and Modifications

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-12 on January 14, extending the safe harbors in Revenue Procedures 2020-26 and 2020-34 to September 30, 2021. This LawFlash discusses the portion of Revenue...more

IRS Provides Interim Guidance on Moving Away From Interbank Offered Rates to Fallback Rates

The Internal Revenue Service (IRS) has issued Revenue Procedure 2020-44 (the Revenue Procedure) providing interim guidance for taxpayers moving away from Interbank Offered Rates (IBORs) to fallback provisions issued by the...more

IRS Releases REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearance and Modifications

The Internal Revenue Service on Monday, April 13 issued welcome relief to the securitization industry, providing that certain forbearances and related modifications to mortgages will generally not cause real estate mortgage...more

Ohio Imposes Tax on Online Retailers with No Physical Presence in State

Ohio Supreme Court decides physical presence is not a necessary condition for imposing commercial activity tax. The Ohio Supreme Court recently ruled that Ohio may impose its commercial activity tax (CAT) on...more

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

IRS Proposes Curtailing “Next-Day Rule” in Corporate Acquisitions

Are you a day late? - On March 5, the Internal Revenue Service (the IRS) published proposed regulations (REG-100400-14, RIN 1545-BM14) (the Proposed Regulations) that would place strict new guidelines on the “next-day...more

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