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U.S. Provides Further Delay for Certain Dividend Equivalent Rules

24 September 2018

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Approved Changes

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United States

On 20 September 2018, the U.S. IRS issued Notice 2018-72, which provides a further delay in the effective/applicability date of certain rules in the section 871(m) regulations concerning dividend equivalents from sources within the United States, as well as an extension for the phase-in period for certain provisions. In general, Notice 2018-72 further extends the extensions provided for in Notice 2017-42 ({News-2017-08-09/A/4-previous coverage}). In particular, Notice 2018-72 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 2021, and that the good faith...