LIBOR Transition and Uncertain Tax Consequences: Our Request To the IRS and Treasury (April 2019)

The Structured Finance Industry Group (“SFIG”) respectfully requests that the Treasury Department and the Internal Revenue Service remove a current source of market uncertainty by issuing guidance that will relieve the many issuers and holders of outstanding debt instruments, especially structured debt instruments, from the potentially severe tax consequences resulting from the anticipated replacement of interest rates based on LIBOR with interest rates based on alternative indices.