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Clifford Chance

Clifford Chance
Briefings

Briefings

Interim Guidance Provided by Revenue Procedure Facilitates LIBOR Transition

November 10, 2020

The Internal Revenue Service recently issued Revenue Procedure 2020-44, which is intended to facilitate the market's transition from the London Interbank Offered Rate and other interbank offered rates to alternative reference rates through the adoption of fallback language developed by the Alternative Reference Rates Committee or the International Swaps and Derivatives Association.  This revenue procedure is effective for modifications to contracts occurring on or after October 9, 2020 and before January 1, 2023.  U.S. taxpayers, however, may rely on Revenue Procedure 2020-44 for modifications to contracts occurring before October 9, 2020.

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