U.S.A.: Notice 2017-42: One-year extension of certain existing section 871(m) rules


The U.S. Internal Revenue Service (IRS) issued Notice 2017-42 on 4 August 2017, that provides a one-year extension of certain parts of the final and temporary regulations issued under sections 871(m), 1441, 1461 and 1473 of the U.S. Internal Revenue Code (IRC) (collectively referred to as Section 871(m) regulations) for 2018 and 2019.

The Notice 2017-42 provides an extension of:

  • The phase-in year for the delta-one and non-delta one transactions;
  • The simplified standard for determining whether transactions are combined transactions;
  • Phase-in relief for qualified derivatives dealers (QDD).

We will continue to monitor the situation and will provide further information as it becomes available.

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