Par. 2. Section 1.892-4 is amended by: a. Redesignating paragraph (d) as paragraph (d)(1); b. Revising the heading of newly redesignated paragraph (d)(1); and c. Adding paragraphs (d)(2) introductory text and (d)(3) and (4). The revision and additions read as follows:
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(d) Applicability date —(1) In general. * * *
(2) Debt acquisition applicability date. Except as provided in paragraph (d)(3) of this section, paragraph (c)(1) of this section applies to acquisitions of debt on or after the date that is the later of:
(i) The first day of the acquirer's first taxable year beginning on or after [DATE OF PUBLICATION OF FINAL RULE], or
(ii) 90 days after [DATE OF PUBLICATION OF FINAL RULE].
(3) Binding commitment rule. Paragraph (c)(1) of this section does not apply to debt acquired pursuant to a binding commitment entered into before the later of the dates described in paragraphs (d)(2)(i) and (ii) of this section.
(4) Rules for debt acquisitions and commitments before the applicability date. Debt acquired before the later of the dates described in paragraphs (d)(2)(i) and (ii) of this section or pursuant to a binding commitment described in paragraph (d)(3) of this section shall continue to be governed by §§ 1.892-4 and 1.892-4T, as contained in 26 CFR in part 1 in effect on April 1, 2026.