On September 12, the IRS issued Final Treasury Regulations that clarify the circumstances that cause property to be treated as “traded on an established market” for purposes of determining the issue price of a debt instrument that is issued for property.  The Final Regulations broadly define the term “traded on an established market.”  These new rules could create adverse U.S. federal income tax issues for borrowers and certain lenders in connection with certain restructurings, recapitalizations, debt-for-debt exchanges and amendments or modifications to credit agreements and other debt instruments.  Click here to read more.