Bulletin No. 2016–51 December 19, 2016

this notice provides transition relief allowing employers to claim the credit by satisfying the pre-2014 rules.

Notice 2016–76, page 834. The notice provides phased-in the application of the section 871(m) dividend equivalent regulations that were finalized in September of 2015. The notice provides that the section 871(m) regulations: (1) only apply to delta-one transactions in calendar year 2017, and (2) will apply to non-delta-one transactions beginning in calendar year 2018. The notice also provides phased-in enforcement of the section 871(m) regulations, including the qualified derivatives dealer rules.