Section 871(m) is the Internal Revenue Code provision that treats "dividend equivalents" paid under certain contracts as dividends from sources within the Unites States and therefore subject to U.S. withholding tax if paid to a non-U.S. person. In September 2015, the IRS issued final regulations (the "2015 Final Regulations"). In December 2016, the IRS released Notice 2016-76, which announced that the IRS intended to issue additional final regulations. On January 19, 2017, the IRS released new final regulations, temporary regulations (together, the "Final Regulations"), and proposed regulations covering section 871(m) of the Code and related withholding rules. Despite some initial uncertainty, taxpayers are now treating the Final Regulations as effective. The final and temporary regulations provide technical corrections to the 2015 Final Regulations, but otherwise generally adopt the 2015 Proposed Regulations. For a full discussion of the highlights of the New Regulations, together with several significant observations, please see our May 2017 issue of Tax Talk, which may be accessed here.