The IRS released final regulations addressing the tax consequences of transitions from the use of interbank offered rates (IBORs) in debt instruments, derivative contracts, and other financial contracts, to qualified rates.
The regulations (T.D. 9961)—released Dec. 30— affect various financial institutions including banks, insurance companies, real estate mortgage investment conduits, taxpayers that lend or borrow funds at variable rates, taxpayers that issue derivative contracts, and taxpayers engaged in hedging transactions.
The IRS in October 2019 had initially issued proposed regulations (REG-118784-18) providing guidance on the tax consequences of the transition to the ...
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