News & Analysis as of

Proposed Regulation Interest Rates

McDermott Will & Schulte

IRS roundup: August 12 – August 20, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 12, 2025 – August 20, 2025. August 15, 2025: The IRS issued Notice 2025-42, providing guidance consistent with...more

Proskauer Rose LLP

Wealth Management Update - September 2024 - 2

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September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more

Proskauer Rose LLP

Wealth Management Update - September 2024

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The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September applicable federal rate (“AFR”) for use...more

Proskauer Rose LLP

Wealth Management Update - June 2024

Proskauer Rose LLP on

June 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more

McGlinchey Stafford

Welcome to 2024: DIDMCA Opt-Out and True Lender Legislative Proposals to Watch

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The new year brings with it four new jurisdictions to watch regarding proposed true lender legislation and Depository Institutions Deregulation and Monetary Control Act (DIDMCA) opt-outs. The District of Columbia, Florida,...more

Harris Beach Murtha PLLC

Proposed Regulation Would Force Banks to Issue Billions in Long-term Debt

Federal regulators are strongly considering requiring regional and mid-sized banks to issue billions of dollars in long-term debt to guard against more bank failures. This onerous requirement will be difficult and costly...more

ArentFox Schiff

The Long and Winding Road: The End of LIBOR

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USD LIBOR is the last step in the long and winding road that has been LIBOR’s slow demise over the last several years as all other LIBOR instruments worldwide have already substantially transitioned. As taxpayers prepare...more

Proskauer - Employee Benefits & Executive...

42 Years in the Making: PBGC Proposes Regulation on Interest Rate for Withdrawal Liability Calculations

A hotly debated (and litigated) issue for multiemployer pension plans in recent years has been the appropriate interest rate to determine a multiemployer pension plan’s liabilities when calculating the plan’s underfunding for...more

Herbert Smith Freehills Kramer

Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR

On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to taxpayers with respect to the widely reported...more

McDermott Will & Schulte

Weekly IRS Roundup November 30 – December 4, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020... November 30, 2020: After releasing a pre-publication...more

McGuireWoods LLP

IRS Revenue Procedure 2020-44: Floating Rate Fallback Flexibility from the Feds

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The IRS recently released Revenue Procedure 2020-44 (“Rev. Proc. 2020-44”) which provides helpful relief to taxpayers by providing that if a contract referencing an IBOR is modified to incorporate specific ISDA or AARC...more

Holland & Knight LLP

CFPB Issues Proposed Libor Transition Rules

Holland & Knight LLP on

The Consumer Financial Protection Bureau (the Bureau) has issued proposed regulations (Proposed Regulations) to facilitate the transition away from Libor (the London Interbank Offered Rate) in the consumer credit market, and...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Schulte

Weekly IRS Roundup December 2 – 6, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

ArentFox Schiff

The End of Libor

ArentFox Schiff on

For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more

Orrick, Herrington & Sutcliffe LLP

Tax Relief for Replacing LIBOR in Tax-Exempt Debt and Swaps

Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more

Holland & Knight LLP

Treasury Department, IRS Issue Proposed Rules on Tax Impact of Transition from Libor

Holland & Knight LLP on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more

Latham & Watkins LLP

US Treasury Alleviates Tax Risk From Interbank Offered Rates Phase-Out

Latham & Watkins LLP on

The Proposed Regulations allow existing debt and non-debt contracts that now reference LIBOR and other Interbank Offered Rates (IBORs) to transition toward alternative reference rates without triggering tax. Key Points: ...more

Herbert Smith Freehills Kramer

Proposed Regulations Mitigate Tax Issues Lurking in LIBOR-Referencing Debt Instruments and Other Contracts

On Oct. 9, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (the Proposed Regulations) providing taxpayers with broad and flexible guidance on the tax...more

Bracewell LLP

Proposed Rules Addressing LIBOR Phase-out Help Ease Reissuance Concerns

Bracewell LLP on

Since the 2017 announcement that the London interbank offered rate (“LIBOR”) may be phased out after the end of 2021, the municipal finance industry has been concerned that changes to debt obligations and related financial...more

McGuireWoods LLP

Treasury Proposes Guidance to Minimize Tax Consequences of LIBOR Phase-Out

McGuireWoods LLP on

The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of...more

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

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The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the...more

Eversheds Sutherland (US) LLP

Relief for REMICs addressing phaseout of LIBOR

New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, the...more

McDermott Will & Schulte

Weekly IRS Roundup June 3 – 7, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

McDermott Will & Schulte

Weekly IRS Roundup February 25 – March 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

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