Prop. Treas. Reg. § 1.679-7 Applicability dates.

Proposed 2024-05-08 · REG-124850-08 · 89 FR 39440 · Interprets § 679 · Would amend § 1.679-7

Par. 7. Section 1.679-7 is amended by: a. Revising the section heading. b. Adding paragraphs (b)(4) through (b)(7). The revision and additions read as follows:

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(b) * * *

(4) The amendments to §§ 1.679-1(c)(2) and 1.679-1(c)(6) apply for taxable years beginning after the [date of publication of the final regulations in the Federal Register ].

(5) The rules of § 1.679-2(a)(5) apply to loans and the use of trust property after the [date of publication of the final regulations in the Federal Register ].

(6) The rules of § 1.679-2(d) apply to transfers of property after the [date of publication of the final regulations in the Federal Register ].

(7) Section 1.679-4(d) applies to obligations issued or modified after the [date of publication of the final regulations in the Federal Register ]. If an obligation issued on or before the [date of publication of the final regulations in the Federal Register ] is modified after that date, and the modification is a significant modification under § 1.1001-3, the new obligation that is deemed issued in the exchange is treated as issued after the [date of publication of the final regulations in the Federal Register ]. If the modification is not a significant modification under § 1.1001-3, then the original obligation must be retested as of the date of the modification to determine whether the obligation, as modified, satisfies the requirements in paragraph (d)(1), as amended, to be a qualified obligation.