The US IRS on March 4 announced that taxpayers may continue to rely on the exception to United States property in §1.956-2T(b)(1)(xi) past its May 7 sunset date.
The IRS said in Notice 2018-46 that it will issuse tax regulations that provide, similar to the rule in section 956(c)(2)(J), an exception from the definition of US property for an obligation of a United States person to the extent the principal amount of the obligation does not exceed the fair market value of cash and readily marketable securities posted or received as margin or collateral for the obligation in the ordinary course of its business by a United States or foreign person that is a dealer in securities or commodities.
Notice 2018-46 will appear in Internal Revenue Bullitin 2018-21 on May 21.
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