Notice 2016-76, Section 871 guidance

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Dec. 2, 2016

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Issue Number: Notice 2016-76

Inside This Issue

Notice 2016-76 provides for the phased-in the application of the section 871(m) dividend equivalent regulations that were finalized in September of 2015. The notice provides that the section 871(m) regulations: (1) only apply to delta-one transactions in calendar year 2017, and (2) will apply to non-delta-one transactions beginning in calendar year 2018.

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