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1001-3 guidelines (that are not particular so you’re able to LIBOR change), Advised Laws and regulations and Rev. Proc. 2020-44 in order to believe in. Within the Suggested Rules, replacement for from LIBOR generally did not produce a considered exchange for people government income tax motives in the event that: (i) the newest fallback price are a qualifying rate (which had been generally laid out); and you can (ii) the latest fair market value of the instrument following the replacement or addition is substantially equal to the fresh reasonable market value of means through to the replacement or introduction.