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Debt Instruments Internal Revenue Service

Holland & Knight LLP

IRS Updates and Modernizes Rules Governing Utility Securitizations

Holland & Knight LLP on

Since the issuance of Revenue Procedure (Rev. Proc.) 2005-62, many utilities have used securitizations authorized by state law to secure collections of stranded costs upon the retirement of certain generation plants or costs...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more

Dechert LLP

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

Dechert LLP on

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

Partridge Snow & Hahn LLP

IRS Issues Final Regulations on Transition from IBORs to Other Reference Rates

The IRS has issued final regulations governing the tax consequences of transitions from Interbank Offered Rates (IBORs) to other reference rates in debt instruments. The final regulations adopt many of the proposed...more

Miller Nash LLP

Today in Tax: Financial Contract Modification and Foreign Tax Credits

Miller Nash LLP on

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

Cadwalader, Wickersham & Taft LLP

IRS Publishes Final IBOR Transition Regulations

On December 30, 2021, the Treasury Department and IRS issued final regulations to address the taxability of modifications that replace LIBOR or another interbank offered rate (an IBOR) with a qualified rate like SOFR....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

McDermott Will & Emery

Weekly IRS Roundup February 15 – February 19, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 15, 2021 – February 19, 2021. Additionally, for continuing updates on the tax impact of...more

Morgan Lewis

IRS Extends REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearances and Modifications

Morgan Lewis on

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-12 on January 14, extending the safe harbors in Revenue Procedures 2020-26 and 2020-34 to September 30, 2021. This LawFlash discusses the portion of Revenue...more

BCLP

IRS Releases December 2020 Interest Rates

BCLP on

The 7520 rate for December 2020 increased to 0.6%. The December 2020 Applicable Federal Interest Rates can be found here. ...more

Kramer Levin Naftalis & Frankel LLP

Treasury and the IRS Finalize Without Change October 2016 Proposed Regulations Treating Certain Related-Party Corporate Debt as...

On May 13, 2020, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) released regulations finalizing previously proposed regulations under Internal Revenue Code Section 385 regarding the...more

Morgan Lewis

IRS Releases REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearance and Modifications

Morgan Lewis on

The Internal Revenue Service on Monday, April 13 issued welcome relief to the securitization industry, providing that certain forbearances and related modifications to mortgages will generally not cause real estate mortgage...more

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: IRS Issues Securitization Guidance on Coronavirus-Related Forbearances

On April 13, 2020, the Internal Revenue Service issued a helpful revenue procedure that permits loans that are subject to certain forbearances and related modifications as a result of the COVID-19 pandemic to be contributed...more

A&O Shearman

Section 385 Treasury Regulations Developments

A&O Shearman on

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

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

Kramer Levin Naftalis & Frankel LLP

Proposed Regulations Mitigate Tax Issues Lurking in LIBOR-Referencing Debt Instruments and Other Contracts

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

Dechert LLP

Proposed Tax Rules on LIBOR Replacements Answer Some (But Not All) Questions

Dechert LLP on

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

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

Dechert LLP

New Proposed Tax Regulations on Replacing LIBOR with Other Variable Rates

Dechert LLP on

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

A&O Shearman

Treasury and the IRS Release Tax Guidance on the Transition from Interbank Offered Rates

A&O Shearman on

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

A&O Shearman

Tax Guidance on the Transition From Interbank Offered Rates Under OIRA Review

A&O Shearman on

On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the “Proposed Regulations”) to the Office of Management...more

Latham & Watkins LLP

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

Latham & Watkins LLP on

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

A&O Shearman

One-Year Delay to the Application of Section 385 Documentation Rules

A&O Shearman on

On July 28, 2017, the Treasury Department and the IRS announced in Notice 2017-36 (the “Notice”) that they will delay the documentation rules of Treasury regulation section 1.385-2 to debt instruments issued or deemed to be...more

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