On 17 September 2020, the United States (US) Department of the Treasury (Treasury) and Internal Revenue Service (IRS) announced (Notice 2020-73) their intent to amend the final Internal Revenue Code1 Section 987 regulations issued in 2016 (T.D. 9794, the 2016 Final Regulations), as well as certain related final regulations issued in 2019 (T.D. 9857, the 2019 Final Regulations), to further delay their applicability date by one additional year (e.g., to 2022 for calendar-year taxpayers).2Background2016 Final, temporary and proposed regulationsOn 8 December 2016, Treasury and the IRS published final (T.D. 9794), temporary (T.D. 9795) and proposed regulations (REG-128276-12) under Section 987. The 2016 Final Regulations provide...