Podcast: Credit Funds: Credit Default Swaps in the Distressed Limelight
Podcast: Credit Funds: What Managers Need to Know and Practical Tips to Avoid Insider Trading Risks
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
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
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
The Proposed Regulations allow existing debt and non-debt contracts that now reference LIBOR and other Interbank Offered Rates (IBORs) to transition toward alternative reference rates without triggering tax. Key Points: ...more
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
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
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