The U.S. IRS has issued Notice 2020-02 announcing that Treasury and the IRS intend to amend the section 871(m) regulations to delay the effective/applicability date of certain rules in those final regulations and extends the phase-in period provided in Notice 2018-72 by two years through 2022. In particular, this includes:

• An extension of the phase-in year for delta-one and non-delta-one tran…