Par. 9. Sections 1.6048-1 through 1.6048-7 are added to read as follows:
(a) In general. The rules of §§ 1.6048-1 through 1.6048-4 and § 1.6048-6 apply as follows:
(1) Section 1.6048-1 applies after the [date of publication of the final regulations in the Federal Register ].
(2) To the extent related to § 1.6048-2, including the relevant portions of § 1.6048-6, the rules apply to reportable events occurring after the [date of publication of the final regulations in the Federal Register ].
(3) To the extent related to § 1.6048-3, including the relevant portions of § 1.6048-6, the rules apply to taxable years of U.S. persons beginning after the [date of publication of the final regulations in the Federal Register ].
(4) To the extent related to § 1.6048-4, including the relevant portions of § 1.6048-6, the rules apply to distributions received after the [date of publication of the final regulations in the Federal Register ].
(b) Special rule for § 1.6048-5. Section 1.6048-5 applies as follows—
(1) To the extent related to reportable events under section 6048(a) and the regulations under section 6048 in this part, the rules apply to reportable events occurring after the [date that final regulations are published in the Federal Register ].
(2) To the extent related to ownership of a foreign trust under section 6048(b) and the regulations under section 6048 in this part, the rules apply to taxable years of U.S. owners beginning after the [date that final regulations are published in the Federal Register ]; and
(3) To the extent related to distributions from a foreign trust under section 6048(c) and the regulations under section 6048 in this part, the rules apply to distributions received after the [date that final regulations are published in the Federal Register ].