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 A domestic base as an organisational unit eligible for a works council – no... legal updates October 07, 2026 EU: Proposed KIDS Act Targets Online Child Safety legal updates October 07, 2026 Supervisory Board election – the main election committee must scrutinise th... legal updates October 07, 2026 Commercially Connected Shorts - 7 October 2026 firm news October 07, 2026 Faster deals, deeper diligence: AI is transforming the legal landscape of M... firm news October 05, 2026 Leading finance partner joins Eversheds Sutherland firm news October 01, 2026 Eversheds Sutherland Switzerland appoints Dr. Michael Faske as new Partner deal alerts September 25, 2026 Eversheds Sutherland is advising Goodyear on the sale of its long-standing ... Events And Training virtual Energy Transition Series: Energy Transition and Pricing Volatility October 08, 2026 10:00 ET | 15:00 BST | 16:00 CET in-person Labor relations conference - turning legal change into workplace reality October 08, 2026 10.00am - 4.00pm (BST) London, United Kingdom virtual Immigration UK – Right to work and compliance masterclass October 15, 2026 9.30am - 12.30pm (GMT) Virtual |