The U.S. IRS has issued Notice 2020-73, which announces an additional one-year delay in the applicability date for final regulations (TD 9794) and related final regulations (TD 9857). Final regulations (TD 9794) were originally published on 8 December 2016 with a one-year transitional period and final regulations (TD 9857) were published on 13 May 2019, replacing temporary regulations (9795), which were also published on 8 December 2016.
Final regulations (TD 9794) concern the determination…