The IRS delayed implementing certain rules that are intended to prevent non-U.S. persons from using derivative instruments to avoid U.S. withholding tax on U.S. equities.
In Notice 2020-2, the IRS reported that both the effective date for Section 871(m) and the phase-in period in Notice 2016-76 will be delayed for two additional years.
The anti-abuse rule will continue to apply during the phase-in years.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
