PRESS RELEASE
4 May 2021

IBOR Transition: Current Status Of US Federal Tax Guidance

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Mayer Brown

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Mayer Brown is a distinctively global law firm, uniquely positioned to advise the world’s leading companies and financial institutions on their most complex deals and disputes. We have deep experience in high-stakes litigation and complex transactions across industry sectors, including our signature strength, the global financial services industry.
For US federal tax purposes, the main consideration for replacing an interbank offered rate (IBOR) with a fallback rate (or of adding a fallback mechanic to an existing instrument)...
United States

May 12, 2021 Webinar
11:00am – 12:00pm EDT
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For US federal tax purposes, the main consideration for replacing an interbank offered rate (IBOR) with a fallback rate (or of adding a fallback mechanic to an existing instrument) is that this alteration could result in a deemed exchange of the instrument (with tax consequences for both the issuer of the instrument and the holder of the instrument).

Guidance for addressing the US federal tax consequences of an IBOR with a successor rate resides in three areas:

  • Older rules for addressing the US tax consequences for amendments to debt in general;
  • Treasury Regulations initially proposed in 2019; and
  • An IRS Revenue Procedure released in 2020.

Hosted by Intelligize, join Mayer Brown experts, Thomas Humphreys and Brennan Young, as they provide an overview of IBOR replacement under current federal tax guidance and a discussion of practical considerations in connection with various different types of instruments.

Contributor

Mayer Brown is a distinctively global law firm, uniquely positioned to advise the world’s leading companies and financial institutions on their most complex deals and disputes. We have deep experience in high-stakes litigation and complex transactions across industry sectors, including our signature strength, the global financial services industry.

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