On March 22, 2017, the SEC adopted an amendment to its rules under the Securities Exchange Act of 1934 that shortens the standard settlement cycle for most broker-dealer transactions from three business days after the trade date ("T+3") to two business days after the trade date ("T+2") beginning September 5, 2017.9 Some older IRS Revenue Rulings and Private Letter rulings consider the difference between the trade date and the settlement date for making determinations such as when gain or loss is recognized on a short sale and the holding period of stock traded on an established securities market.10 Perhaps it is time for clarification on those rulings that they now apply to the T+2 settlement cycle. However, given the general freeze on IRS guidance,11 that may not be likely.