Some Guidance Relating to Transitions Away from LIBOR
The Treasury Department and the Internal Revenue Service have provided advance guidance in Rev. Proc. 2020-44 to allow the implementation of fallback regimes developed by the Alternative Reference Rate Committee and the International Swaps and Derivatives Association to facilitate the orderly transition away from interbank offered rates in certain contracts. This transition is expected to occur at the end of 2021 in accordance with the announcement made by the Financial Conduct Authority, which regulates and oversees the London Interbank Offered Rate. To the extent a contract is modified in accordance with such fallback regimes, under Rev. Proc. 2020-44 the modification will not result in a taxable event to either the investor or the issuer.
Also of Interest
- New Private Activity Bond Provisions for Qualified Carbon Dioxide Capture Facilities
A new category of tax-exempt private activity bonds was created as part of the Infrastructure Investment and Jobs Act, enacted in November 2021, to encourage private investment in carbon dioxide capture facilities.
- Final Treasury Reissuance Regulations Addressing Modifications of Debt Instruments to Replace IBORs
This edition of the Hawkins Advisory describes recently released final Treasury Regulations providing guidance in connection with the discontinued Interbank Offered Rates.
- Tax-Exempt Bond Provisions Included in the Infrastructure Investment and Jobs Act
This Hawkins Advisory describes three tax-exempt bonds provisions included in the Infrastructure Investment and Jobs Act.
- 2021 Area Median Gross Income Figures
On March 25, 2021, the Internal Revenue Service released Revenue Procedure 2021-19, which contains information for issuers of single-family housing bonds and mortgage credit certificates related to the income limits.