The U.S. IRS has issued Notice 2022-37 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 regulations by a further two years. 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 2025, and that the good faith efforts standard will be applied for any delta-one transactions in 2017 through 2024 and to any non-delta-one transactions in 2025, An extension through 2024 of the period during...