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 transactions, including that section 871(m) regulations will not apply to non-delta-one transactions issued before 1 January 2023, and that the good faith efforts standard will be applied for any delta-one transactions in 2017 through 2022 and to any non-delta-one transactions...