Revenue Procedure 2020-44; to facilitate the market’s transition away from the London Interbank Offered Rate and other interbank offered rates, this revenue procedure mitigates certain potential tax consequences of adopting fallback language recommended by the Alternative Reference Rates Committee (“ARRC”) and the International Swaps and Derivatives Association (“ISDA”).  The revenue procedure generally provides that modifying certain contracts to incorporate the ARRC’s and ISDA’s recommended fallback language will not result in a realization event.  In addition, the revenue procedure generally provides that such modifications will not result in legging out of an integrated transaction or in the disposition or termination of either leg of a hedging transaction.

Revenue Procedure 2020-44 will appear in IRB 2020-45, Nov. 2, 2020.