This week the Internal Revenue Service and Department of the Treasury published in the Federal Register final guidance on the transition away from LIBOR. The final regulations address circumstances when modifying a contract to update its reference rate that may result in a tax consequence. These final regulations will take effect March 7.
The final regulations exclude the “substantially equivalent” requirement that was originally proposed, which was a significant concern raised by SFA in its advocacy.
SFA will be hosting a Tax Policy Committee call to discuss the final guidance with respect to the LIBOR transition and will discuss further within the SFA LIBOR Task Force. If you are interested in joining the conversation, please reach out to Jeff Gudiel.