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Notice 2019-58, page 1022.

Internal Revenue Bulletin 2019-44 · 2026-10-03 edition · updated 2026-10-04 · United States

This notice announces that, following the expiration of the temporary regulations under section 385, taxpayers may rely on the notice of proposed rulemaking cross-referencing the temporary regulations.

REG-118784-18, page 1024. The proposed regulations provide guidance on the tax consequences of the phased elimination of interbank offered rates (IBORs) that is expected to occur in the United States and many foreign countries. The proposed regulations generally

Finding Lists begin on page ii.

provide that modifying a debt instrument, derivative, or other contract to replace an IBOR-referencing rate (or to revise fallback provisions in anticipation of the elimination of an IBOR) is not treated as a realization event for purposes of section 1001. The proposed regulations also adjust other tax rules, such as the OID and REMIC rules, to minimize the collateral consequences of the elimination of IBORs.

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▸Contents — Internal Revenue Bulletin 2019-44

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