N-18-46: Modifications to Definition of United States Property under Section 956

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May 4, 2018

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Issue Number: N-2018-46

Inside This Issue

Notice 2018-46 allows taxpayers to continue to rely on the exception to United States property in §1.956-2T(b)(1)(xi) past its May 7, 2018, sunset date and announces the intention to publish regulations that will provide, similar to the rule in section 956(c)(2)(J), an exception from the definition of U.S. property for an obligation of a United States person to the extent the principal amount of the obligation does not exceed the fair market value of cash and readily marketable securities posted or received as margin or collateral for the obligation in the ordinary course of its business by a United States or foreign person that is a dealer in securities or commodities.

It will appear in IRB 2018-21 dated May 21, 2018.

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