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Market Reactions to IBOR Transition Proposed Tax Regulations  


Author:  Mark Howe.; Alissa Kalinowski.; Tara McCarney.


Source: Volume 38, Number 01, Fall 2020 , pp.23-34(12)




Journal of Taxation of Investments

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Abstract: 

While the Proposed Regulations issued on October 9, 2019, provide some meaningful guidance on the tax implications of modifying both debt instruments and non-debt contracts to account for the cessation of IBOR-referencing rates, industry participants have noted several outstanding issues. This article discusses the concerns posed by industry participants and their recommendations to address the gaps in the Proposed Regulations.

Keywords: Prop. Reg. Sec. 1.1001-6, IBOR, reference rate, significant modification

Affiliations:  1: Cadwalader, Wickersham & Taft LLP; 2: Cadwalader, Wickersham & Taft LLP; 3: Cadwalader, Wickersham & Taft LLP.

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