News & Analysis as of

Libor Internal Revenue Code (IRC)

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

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

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

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

ArentFox Schiff

The End of Libor

ArentFox Schiff on

For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...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

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

Orrick - Finance 20/20

U.S. Treasury Issues Guidance on the Transition from Interbank Offered Rates to Other Reference Rates

Orrick - Finance 20/20 on

The U.S. Department of the Treasury issued proposed regulations that provide guidance on the transition from LIBOR. One set of such regulations provides that substituting a “qualified rate,” such as the Secured Overnight...more

Troutman Pepper

Tax Proposals to Eliminate Interest Deductions Miss the Mark

Troutman Pepper on

The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

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