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
10/11/2019
/ Comment Period ,
Debt Instruments ,
Foreign Banks ,
Hedges ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
IRS ,
Libor ,
Proposed Amendments ,
Proposed Regulation ,
REMIC ,
Secured Overnight Funding Rate (SOFR) ,
Sterling Overnight Index Average (SONIA) ,
Treasury Regulations ,
U.S. Treasury ,
Variable Rates
The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more
10/26/2016
/ Capital Expenditures ,
Debt ,
Debt Financing ,
Disguised Sales ,
Final Rules ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Risk Allocation ,
Tax Structuring ,
U.S. Treasury