Response to Proposed Regulations Relating to Tax Consequences of IBOR Transitions

Comments sent to the Internal Revenue Service (IRS) and the U.S. Department of Treasury’s Office of Tax Policy (OTP) with respect to Prop. Treas. Reg. Section 1.1001-6 and the proposed amendment to Treas. Reg. Section 1.1275-2 contained in REG-118784-18 relating to tax consequences of the transition to the use of reference rates other than interbank…