Title 26

SECTION 1.951A-7

1.951A-7 Applicability dates.

§ 1.951A-7 Applicability dates.

(a) In general. Except as otherwise provided in this section, sections 1.951A-1 through 1.951A-6 apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.

(b) High-tax exception. Section 1.951A-2(c)(1)(iii), (c)(3)(ii), and (c)(7) and (8) apply to taxable years of foreign corporations beginning on or after July 23, 2020, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. In addition, taxpayers may choose to apply the rules in § 1.951A-2(c)(1)(iii), (c)(3)(ii), and (c)(7) and (8) to taxable years of foreign corporations that begin after December 31, 2017, and before July 23, 2020, and to taxable years of U.S. shareholders in which or with which such taxable years of the foreign corporations end, provided that they consistently apply those rules and the rules in § 1.954-1(c)(1)(iii)(A)(3), § 1.954-1(c)(1)(iv), and the first sentence of § 1.954-1(d)(3)(i) to such taxable years.

(d) Deduction for disqualified payments. Section 1.951A-2(c)(6) applies to taxable years of foreign corporations ending on or after April 7, 2020, and to taxable years of United States shareholders in which or with which such taxable years end.

[T.D. 9866, 84 FR 29341, June 21, 2019, as amended by T.D. 9902, 85 FR 44648, July 23, 2020; T.D. 9922, 85 FR 72070, Nov. 12, 2020]