The IRS has modified the effective date of Rev. Proc. 2016-44 to extend the transition period by 6 months.
The revision allows an issuer to apply the safe harbors in Rev. Proc. 97-13, as modified and amplified, to a management contract entered into before August 18, 2017 and that is not materially modified or extended on or after August 18, 2017 (other than pursuant to a renewal option as defined in sec. 1.141-1(b)).
The August 18, 2017 date is 6 months later than previously announced.
The updated version will be printed in next week’s Internal Revenue Bulletin.
The revised version of Rev. Proc. 2016-44 is available here.