U.S. Section 871(m)

U.S. Section 871(m)

Section 871(m) is one of the most complex areas of cross border tax regulation for financial institutions
If you trade in derivatives that have underlying U.S. stocks, we can help


How we support financial institutions with Section 871(m):

Exposure Map Report

If you are not sure whether or how much you are affected by Section 871(m), we can provide an exposure map report that will give you:

  1. A clear picture of how you are or will be impacted by the Section 871(m) regulations
  2. Whether you meet the IRS Good Faith Efforts standard
  3. An overview of the operational choices available to you
  4. Practical recommendations to remediate any issues

Compliance Manual Development

We provide expert support to help you build a comprehensive compliance system that allows you to effectively manage your exposure to Section 871(m) and meet the IRS’ good faith efforts standard.

We make sure that your compliance manual is practical, easy to use, and can evolve with you as you add new derivative products to your portfolio.


We can deliver bespoke training to help your staff understand how Section 871(m) works and what it means to be a Qualified Derivatives Dealer (QDD).

We can provide training remotely via video call or on site. All courses are tailored to your needs and can be delivered as high-level briefing sessions or operational deep dives.

QDD Compliance Review

Our compliance reviews help QDDs to assess their current level of compliance and identify areas for improvement.

We review a sample of accounts, your compliance manual and related materials, and conduct interviews with key members of staff to get a holistic view of your controls.

Retained Subject Matter Expertise

We can be on hand to answer day-to-day operational questions about Section 871(m), either on an ad hoc basis or as your retained subject matter experts.

We provide non-legally binding opinion that is practical and to the point, so your operations team can make quick, informed decisions and get on with the job.

Start complying with Section 871(m)

If you think your firm may be exposed to Section 871(m), get an expert review of your current level of compliance and an action plan to help you choose the right path for your firm.


“Many firms are struggling to develop systems and procedures to meet these complex rules. Getting Section 871(m) right will significantly reduce compliance risk for institutions that trade in derivative instruments.”

Ross McGill, Chairman


+44 (0) 1252 413551