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May 22, 2024

IRS extends transition relief for dividend equivalent transactions under IRC Section 871(m)

The IRS today in Notice 2024-44 (Notice) extended by two years the phased-in application of IRC Section 871(m) regulations as they apply to delta-one and non-delta-one derivative transactions and the simplified standards for withholding agents to determine whether transactions are combined transactions. The Notice also extends until 2027 the implementation of the net delta exposure method for determining withholding liability of qualified derivatives dealers. A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor