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Technical Update- September International Tax Alert

Notice 2017-42 Delays Effective/Applicability Dates in Dividend Equivalent Rules

 

Summary

Notice 2017-42 (the “Notice”) provides taxpayers with additional guidance for complying with final and temporary regulations under Sections 871(m), 1441, 1461, and 1473 of the Internal Revenue Code (collectively referred to as the “Section 871(m) regulations”) in calendar year 2018 and 2019. The Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) announced in the Notice their intention to amend the Section 871(m) regulations to delay the effective/applicability date of certain rules in those final regulations and also extend the phase-in period provided in Notice 2016-76 for certain provisions of the Section 871(m) regulations.  Read more