New IRS IBOR/SOFR rules do not fully resolve calculation challenges for debt commentary

The IRS released proposed regulations (REG-118784-18, the “IBOR Conversion Proposed Regulations”) that in general favorably address a number of the U.S. federal income tax consequences of the conversion of existing debt instruments and non-debt contracts from interbank offered rates (“IBOR”s, which include various LIBOR or London Interbank Offered Rates) to an alternative reference rate. Read our commentary.