Prop. Treas. Reg. § 1.961-14 Applicability dates.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 961

Par. 28. Sections 1.961-3 through 1.961-14 are added to read as follows:

(a) Scope. This section sets forth applicability dates for the section 961 regulations. Paragraph (b) of this section provides the applicability dates.

(b) Applicability dates. Sections 1.961-1 through 1.961-5 and 1.961-8 through 1.961-13 apply to taxable years of foreign corporations that begin on or after [date of publication of final regulations in the Federal Register ] or are early application years (as described in § 1.959-12(d)) and to taxable years of persons for which such taxable years of those foreign corporations are relevant.