U.S. IRS Provides Further Delay for Certain Dividend Equivalent Rules

The U.S. IRS has issued Notice 2022-37 announcing that Treasury and the IRS intend to amend the section 871(m) regulations to delay the effective/applicability date of certain rules in those regulations by a further two years. In particular, this includes:
- An extension of the phase-in year for delta-one and non-delta-one transactions, including that section 871(m) regulations will not apply t…