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Instead of trying to be everything to everybody, we’ve made a name for ourselves by delivering what our clients need most: in-depth, hands-on legal counsel throughout the financial services sector — and beyond.

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  • New York

    • 919 Third Avenue
    • New York, NY 10022
    • United States of America
      • +1 212.756.2000 Phone
      • +1 212.593.5955 Fax
  • Washington, DC

    • 901 Fifteenth Street, NW, Suite 800
    • Washington, DC 20005
    • United States of America
      • +1 202.729.7470 Phone
      • +1 202.730.4520 Fax
  • London

    • One Eagle Place
    • London SW1Y 6AF
    • United Kingdom
      • +44 (0) 20 7081 8000 Phone
      • +44 (0) 20 7081 8010 Fax

On Dec. 30, 2021, the Treasury Department and the Internal Revenue Service issued final regulations to address whether modifications that replace LIBOR or another interbank offered rate (“IBOR”) with a qualified rate like the Secured Overnight Financing Rate (“SOFR”) are taxable. SOFR is the fallback to USD LIBOR recommended by the Alternative Reference Rates Committee (“ARRC”). The final regulations apply to all modifications, whether effected through an amendment, an exchange, a retirement and reissuance, or otherwise, and to all contracts (defined broadly to include all debt, equity, and derivative instruments), and take effect 60 days following the publication of the regulations in the federal register on Jan. 4, 2022. Taxpayers may rely on the regulations for earlier modifications of contracts if they and their related parties apply the regulations to all modifications of the terms of such contracts.

Under the final regulations, a covered modification is not treated as the “exchange of property for other property differing materially in kind.” Covered modifications include modifications where:

  1. The terms of the contract are modified to replace an operative rate that references a discontinued IBOR with a qualified rate, to add an obligation for one party to make a qualified one-time payment (if any), and to make associated modifications (if any).
  2. The terms of the contract are modified to include a qualified rate as a fallback to an operative rate that references a discontinued IBOR and to make associated modifications (if any); and
  3. The terms of the contract are modified to replace a fallback rate that references a discontinued IBOR with a qualified rate and to make associated modifications (if any).

Qualified rates are defined to include, among others, alternative, substitute, or successor rates selected, endorsed, or recommended by the central bank, reserve bank, monetary authority or similar institution (including any committee or working group thereof) as a replacement for a discontinued IBOR or its local currency equivalent in that jurisdiction and rates selected, endorsed, or recommended by the ARRC.

Modifications might have covered and noncovered components. Covered modifications (which can include technical, administrative, operational or other associated modifications) can include qualified one-time payments used to compensate parties for differences between the discontinued and replacement rate. Noncovered modifications (defined as any modifications that are not covered modifications) are tested on a standalone basis under the general modification rules to determine whether they cause a taxable event. When a noncovered modification is effected contemporaneously with a covered modification, taxpayers must test the noncovered modification as if the contract already included the covered modification.

Key Publication

The IRS Final Regulations Concerning the Transition from Interbank Offered Rates to Other Reference Rates