On December 30, 2021, the Internal Revenue Service (IRS) published final regulations for the IBOR transition. This Legal Update provides background on the principle US federal income tax concern with IBOR-related amendments to existing contracts and an overview of previous IRS guidance aimed at addressing the concern. The Update then discusses the types of modifications

On Friday, October 9, 2020, the Internal Revenue Service released Revenue Procedure 2020-44 (the “Revenue Procedure”), providing retroactive but limited relief for amending specific types of legacy contracts to add fallback mechanics for the London Interbank Offer Rate or other Interbank Offer Rates. The fallback granted relief by the Revenue Procedure must rather strictly follow

Businesses are under unprecedented stress due to the global COVID-19 pandemic. Many of these businesses need some form of relief on their debt obligations in order to avoid triggering defaults, foreclosures and collection activity during this extraordinary period of economic inactivity.  There is no one way to structure a workout.  The workout structure can be