Par. 32. Section 1.965-9 is amended by adding paragraph (d) to read as follows:
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(d) Applicability date for adjusted applicable percentage. Section 1.965-5(d)(5) applies 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.