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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...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
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
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
New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, the...more
On October 9, 2019, the U.S. Department of the Treasury and the Internal Revenue Service proposed regulations (“Proposed Regulations”) addressing the transition from London interbank offered rate (“LIBOR”) to the use of...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
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more