Par. 9. Newly redesignated § 1.987-17 is amended by adding paragraphs (e) and (f) to read as follows:
* * * * *
(e) Applicability date of 120-month amortization rule. Section 1.987-10(e)(5)(ii) applies to taxable years beginning after December 31, 2024, and ending on or after November 25, 2025. See § 1.987-15, as contained in 26 CFR in part 1 in effect on April 1, 2025, for a prior applicability date for § 1.987-10(e)(5)(ii).
(f) Applicability date of rules relating to the CFC exemption election. Sections 1.987-1(g)(2)(iv) and (g)(3)(ii)(D), 1.987-6(b)(1)(v) and (vi), 1.987-7(b)(2), (c)(2)(iv), and (d)(2)(iv), and 1.987-15 apply to taxable years ending on or after [date of filing of final regulations with the Federal Register ]. Section 1.987-16 applies to transactions completed within taxable years of a domestic acquiring corporation ending on or after [date of filing of final regulations with the Federal Register ]. See § 1.987-15, as contained in 26 CFR in part 1 in effect on April 1, 2025, for a prior applicability date for § 1.987-7(b).