The IRS issued final regulations removing "minimum documentation requirements that ordinarily must be satisfied in order for certain related-party interests in a corporation to be treated as indebtedness for Federal tax purposes."
Cadwalader attorneys reviewed recently proposed IRS regulations confirming that transitions from LIBOR and other interbank offered rates to alternative reference rates in debt instruments and derivatives will not be taxable events.
The IRS proposal amending certain regulations to address the transition from interbank offered rates to other reference rates for debt instruments and non-debt contracts was published in the Federal Register.
An investment fund challenged an IRS determination that various contracts entered into between the fund and an investment bank resulted in the fund having effective ownership of the positions that were the subject of the contracts.
U.S. Treasury Deputy Secretary Justin Muzinich highlighted developments in housing finance reform, Committee on Foreign Investment in the United States reform, digital taxation, and cryptocurrency policy.