U.S.A.: Section 871(m) - IRS publishes Notice 2022-37


The IRS has released Notice 2022-37 on 23 August 2022.

The notice announces an additional two-year extension for taxpayers to comply with the final regulations, with respect to section 871(m) regulations.

  • The phase-in period provided in the Notice 2020-2 (T19026) for certain provisions of section 871(m) regulations is extended.
  • Among others, Section 871(m) rules would not apply to any payment made with respect to any non-delta one transaction issued before 1 January 2025.

We will continue to monitor the IRS publications and will provide customers with further information in due course.

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