The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal
Russell E. Nance
US IRS Releases Final Regulations Addressing IBOR Transition
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…
Limited US Tax Guidance for Adding ARRC and ISDA Fallbacks
By Steven D. Garden, Russell E. Nance, Remmelt Reigersman, Brennan W. Young & Thomas A. Humphreys on
Posted in Derivatives, Tax
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…