IRS Amends Effective Date for Dividend Equivalent Payments Under IRC Section 871(m) | Practical Law

IRS Amends Effective Date for Dividend Equivalent Payments Under IRC Section 871(m) | Practical Law

The IRS has eliminated the transitional effective date under IRC Section 871(m) for contracts entered into in 2016.

IRS Amends Effective Date for Dividend Equivalent Payments Under IRC Section 871(m)

Practical Law Legal Update w-001-0305 (Approx. 2 pages)

IRS Amends Effective Date for Dividend Equivalent Payments Under IRC Section 871(m)

by Practical Law Finance
Published on 08 Dec 2015 • USA (National/Federal)
The IRS has eliminated the transitional effective date under IRC Section 871(m) for contracts entered into in 2016.
The IRS and Treasury Department recently issued amendments to regulations under IRC Section 871(m) eliminating the transitional effective date for contracts entered into in 2016. Under the amendments, the regulations now apply to "specified notional principal contracts" and "specified equity-linked instruments" issued on or after January 1, 2017 and do not apply to contracts issued in 2016.
For more information on the IRC Section 871(m) regulations, see Legal Update, IRS Issues Regulations on Dividend Equivalent Payments.