The IRS today released an advance version of Notice 2020-2 announcing additional time for taxpayers to comply with the final and temporary regulations under sections 871(m), 1441, 1461, and 1473.
Regulations released today for publication in the Federal Register finalized rules that were proposed in January 2017 and removed corresponding temporary regulations. Read TaxNewsFlash
Notice 2020-2 [PDF 36 KB] states that Treasury and the IRS intend to revise the regulations and in the meantime provides the following extensions of time:
Notice 2020-2 further provides the anti-abuse rule provided in Reg. section 1.871-15(o) will continue to apply during the phase-in years (described above). As a result, a transaction that would not otherwise be treated as a section 871(m) transaction may nevertheless be a section 871(m) transaction under Reg. section 1.871-15(o).
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