As the IBOR transition continues, business teams have frequently heard from their tax departments and advisors that amending existing contracts to add IBOR replacement mechanics or replacing an IBOR rate with a new rate can...more
On Friday, October 9, 2020, the Internal Revenue Service released Revenue Procedure 2020-44 (the “Revenue Procedure”), providing retroactive but limited relief for amending specific types of legacy contracts to add fallback...more
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
The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019. The Act is designed, among other things, to overhaul and modernize...more
2/12/2020
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Disclosure Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Loans ,
Mortgage Loan Originators ,
Mortgages ,
Personal Information ,
Secondary Markets ,
Structured Finance ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Taxpayer First Act of 2019 (TFA) ,
Transcripts
On December 16, 2019, the IRS released Notice 2020-2 (the “Notice”), which further extends the phase-in of regulations under Section 871(m) of the Code3 (the “Regulations”)4 and related provisions. Section 871(m) and its...more