Additional Guidance on the Transition From Interbank Offer Rates to Other Reference Rates With Respect to the Interest Rates of a Foreign Bank

This document contains additional final regulations that provide guidance on the transition away from the use of interbank offer rates ("IBORs") to other reference rates. Specifically, this regulation provides the replacement rate for the IBOR presently used in the published rate election, which may be used by taxpayers to determine the amount of interest expense attributable to their excess U.S.-connected liabilities and allocable to income that is effectively connected with the conduct of a trade or business within the United States ("ECI"). The final regulations will affect foreign banks that have income that is ECI.