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In Notice 2021-59, the IRS recently announced its intention to amend regulations under Internal Revenue Code Section 987 to defer the applicability date of certain final regs under Sec. 987 and certain related final regs by one additional year. Here are some pertinent additional details.
In December 2016, the IRS issued final regs under Sec. 987 (the 2016 final regs). Then, in May 2019, the tax agency issued more final regs under Sec. 987 (related 2019 final regs).
The IRS now intends to amend the applicability dates in six of the 2016 final regs and two of the related 2019 final regs to provide that both sets of regs apply to tax years beginning after December 7, 2022 (the amended applicability date).
Thus, following the amendments, the 2016 final regs and the related 2019 final regs would apply to the tax year beginning on January 1, 2023, for calendar-year taxpayers. The IRS doesn’t intend to amend the applicability date of one specific reg (Sec. 1.987-12).
Notice 2021-59 provides more specifics on how a taxpayer can apply the 2016 final regs and the related 2019 final regs before the amended applicability date.
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The information provided in this communication is of a general nature and should not be considered professional advice. You should not act upon the information provided without obtaining specific professional advice. The information above is subject to change.
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