Final IRS LIBOR Transition Guidance
Updated: Sep 21, 2022
Minneapolis, MN | February 7, 2022 | Georgina Walleshauser, Assistant Vice President
The Internal Revenue Service published its final regulations on January 4th for the LIBOR transition. There were several changes from their proposed regulations.
Of note, these changes include the new distinction between covered and non-covered modifications. Covered modifications of contracts will not result in a potential change in the tax status or tax treatment of the original financing. These modifications include replacing the discontinued IBOR rate with a qualified rate and adding or changing a fallback rate to a qualified rate. Covered modifications will not require a tax reissuance of the contract or debt. However, the IRS may be prompted to test the fair market value of the revised contract if there are non-covered modifications such as a change in the timing or amounts of the cashflows.
These regulations will take effect beginning March 7th. For any specific questions regarding the final regulations, please contact your Blue Rose Advisor.
Meet the Author:
Georgina Walleshauser, Assistant Vice President | 952-746-6036
Georgina Walleshauser joined Blue Rose in 2017 as an Analyst, providing modeling, analytics, market data, and research in support of the delivery of capital planning, debt and derivatives advisory, and reinvestment services to our clients. In the role of Associate, she utilized her experience as an Analyst in a more client-facing role, while still performing much of the analysis utilized in this capacity. In her role of Assistant Vice President, she will be tasked with growing client management responsibilities, in particular ensuring that our clients’ transactions run smoothly through closing.
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