IRS again extends Section 871(m) transition relief for dividend equivalent payment rules through 2028
September 30, 2026
IRS again extends Section 871(m) transition relief for dividend equivalent payment rules through 2028September 30, 2026 On September 21, 2026, the Internal Revenue Service (IRS) released Notice 2026-61 (Notice), which further extends by two years phase-in relief for compliance with final regulations under Sections 871(m), 1441, 1461, and 1473 regarding dividend equivalents. For additional background on these rules, see IRS extends relief for Section 871(m) regulations. In extending the relief, Notice 2026-61 provides two clarifications:
Apart from these clarifications and the updated dates, Notice 2026-61 generally continues the relief provided by Notice 2024-44 for tax years 2027 and 2028 without substantive change. ___________ If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work. Latest Insights
Latest News
Latest Events
legal updates October 08, 2026 CFTC issues staff advisory on “mention market” event contracts legal updates October 08, 2026 SEC proposes to modernize performance fee rules and expand accredited inves... legal updates October 08, 2026 The Commercial Payments Bill: Practical Implications for Commercial Contrac... guides and reports October 07, 2026 Technology, AI and the changing legal landscape of M&A client news October 09, 2026 Eversheds Sutherland Advised Pacific Life Re in its $3bn Longevity Reinsura... firm news October 07, 2026 Faster deals, deeper diligence: AI is transforming the legal landscape of M... client news October 06, 2026 Eversheds Sutherland Advises Infranity on Closing of $300 Million Holding C... client news October 06, 2026 Eversheds Sutherland Advises Ives Ultra AI Opportunities Inc. on $200 Milli... virtual Immigration UK – Right to work and compliance masterclass October 15, 2026 9.30am - 12.30pm (GMT) Virtual virtual German employment law training October 20, 2026 2pm - 5pm (GMT) Virtual virtual French employment law training November 03, 2026 2pm - 5pm (GMT) Virtual virtual Dutch employment law training November 10, 2026 2.00pm - 5.00pm (GMT) Virtual |