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ARTICLE · 05 NOVEMBER 2020

IRS Releases Guidance On LIBOR Transition

Stradley Ronon Stevens & Young
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The IRS, in Revenue Procedure 2020-44, provides guidance on the market's transition from the London Interbank Offered Rate (LIBOR) and other rates to alternative reference rates.

United StatesFinance and Banking
Christopher Scarpa
Christopher Scarpa
Jacquelyn Gordon
Jacquelyn Gordon

IRS Releases Guidance on LIBOR Transition

The IRS, in Revenue Procedure 2020-44, provides guidance on the market's transition from the London Interbank Offered Rate (LIBOR) and other rates to alternative reference rates. The Revenue Procedure states that (i) certain modifications to a contract with terms referencing an IBOR (defined below) will not be treated as an exchange of property for other property differing materially in kind or extent for purposes of Section 1.1001-1(a) of the Treasury Regulations; and (ii) such modifications will not be treated as a legging out of an integrated transaction, a termination of a qualified hedge, or as a disposition or termination of either leg of a hedging transaction. (Section references are to the Internal Revenue Code of 1986, as amended and the related Treasury Regulations, as the context requires.)

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