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Foley & Lardner LLP

IRS Proposed Regulations Provide Flexibility for LIBOR Phase-out

Foley & Lardner LLP on

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

Latham & Watkins LLP

US Treasury Alleviates Tax Risk From Interbank Offered Rates Phase-Out

Latham & Watkins LLP on

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

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

Proskauer - Tax Talks on

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

Troutman Pepper

Tax Relief May Be Ahead for Market Participants Transitioning Away From LIBOR

Troutman Pepper on

Tax relief may be coming for issuers and holders of debt instruments and parties to derivatives and other financial contracts governed by LIBOR (the London Interbank Offered Rate). ...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

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