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US Treasury and the IRS recently issued Notice 2022-34, which states plans to defer the applicability date of certain final Section 987 regulations and certain related regulations by an additional year, now to tax years beginning after 7 December 2023. These regulations previously had been deferred under prior Notices, including most recently under Notice 2021-59.

The Notice provides that several of the 2016 final regulations (Secs. 1.861-9T, 1.985-5, 1.987-11, 1.988-1, 1.988-4, and 1.989(a)-1), along with related 2019 final regulations (Secs. 1.987-2 and 1.987-4), will apply to tax years beginning after 7 December 7 2023. Thus, under the Notice, for calendar-year taxpayers the 2016 final regulations and the related 2019 final regulations would apply to the tax year beginning on 1 January 2024.