On Oct. 9, 2020, the Internal Revenue Service issued Rev. Proc. 2020-44 (“Revenue Procedure”) to facilitate the market’s transition from interbank offered rates (“IBORs) to alternative reference rates through the adoption of fallback languages recommended by the Alternative Reference Rates Committee (“ARRC") and the International Swaps and Derivatives Association (“ISDA”). The Revenue Procedure provides guidance on the tax consequences of modifying debt instruments and derivative contracts to replace IBORs or to add fallback provisions to IBORs. The Revenue Procedure provides that if any contract with terms that reference an IBOR are modified to incorporate an ISDA Fallback or an AARC Fallback (as defined in the Revenue Procedure, including permissible deviations), such modification is not treated as an exchange of property for other property differing materially in kind or extent for purposes of the significant modification regulations found in Treasury Regulation Section 1.1001.