On Friday, October 9, 2020, the US 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 LIBOR or other IBORs. The fallback language included must rather strictly follow select model contract language recommended by the Alternative Reference

On February 6, 2020, Russell Nance, Steven Garden and Brennan Young presented an overview of the proposed regulations addressing the US federal tax consequences of replacing an interbank offered rate (IBOR) with a successor rate as part of Mayer Brown’s Global Financial Markets Initiative.

You can listen to the discussion by clicking on the “Listen

Mayer Brown’s Capital Markets Tax Quarterly provides capital markets-related US federal tax news and insights. In this issue of CMTQ, we look at final quarter of 2019. We discuss Section 871(m) phase-in, the Warren wealth tax proposal, and final nonresident alien withholding regulations, among other recent updates.