Debt modifications: What are some key considerations?

Host: Joe Ferst, managing director, Deloitte Tax LLP
1 Overview CPE credit | Taxes

Companies routinely modify the terms of outstanding debt instruments. Modifications that are considered to be significant under the rules of Treas. Reg. § 1.1001-3 result in a deemed satisfaction and reissuance of the outstanding debt. In light of the regulations, what are the important considerations when modifying the terms of debt? We'll discuss:

• The general rules for debt modifications under Treas. Reg. § 1.1001-3.
• The latest thinking on extensions of maturity outside the regulation's safe harbor.
• Considerations involving debt modifications and disregarded entities.

Participants will explore ways to modify terms of outstanding debt instruments while complying with the rules associated with financing transactions.