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September 17, 2020

IRS again delays applicability date for certain IRC Section 987 foreign currency regulations

The IRS has announced (Notice 2020-73) that it intends to defer, for one more year, the applicability date of the final regulations under IRC Section 987 and certain related regulations. Prior notices had deferred the applicability date to tax years beginning after December 7, 2020 (see Tax Alert 2019-2179). Notice 2020-73 lists the following regulation sections as those that will be amended to apply to tax years beginning after December 7, 2021: Reg. Sections 1.861-9T, 1.985-5, 1.987-2, 1.987-4, 1.987-11, 1.988-1, 1.988-4 and 1.989(a)-1.

A Tax Alert on the notice is forthcoming.