On December 2, 2016, the IRS released Notice 2016-76 and followed through on its promise to provide taxpayers with guidance for complying with IRC Section 871(m) regulations. In the Notice, the Treasury Department and the IRS announced their intention to amend the IRC Section 871(m) regulations to phase in the application of certain rules to facilitate implementation of the regulations. The Notice acknowledged taxpayers' challenges in complying with certain aspects of the IRC Section 871(m) regulations and provides some relief. Most significantly, the Notice announces the Treasury Department's and the IRS's intention that the effective date for the application of Section 871(m) be January 1, 2017, for delta-one instruments and January 1, 2018, for non-delta-one instruments. See our client alert at https://media2.mofo.com/documents/161206-irs-guidance-871m.pdf.