Reg. § 1.267A-7 Applicability dates.
(a) General rule Except as provided in of this section, through apply to taxable years ending on or after December 20, 2018, provided that such taxable years begin after December 31, 2017. However, taxpayers may apply the regulations in through in their entirety (including by taking into account of this section) for taxable years beginning after December 31, 2017, and ending before December 20, 2018. In lieu of applying the regulations in through (including of this section), taxpayers may apply the provisions matching through (including by taking into account the provision matching of this section) from the Internal Revenue Bulletin (IRB) 2019-03 (https://www.irs.gov/pub/irs-irbs/irb19-03.pdf) in their entirety for all taxable years ending on or before April 8, 2020.
(b) Special rules The following special rules apply regarding applicability dates:
(1) Sections (payments pursuant to interest-free loans and similar arrangements), (b) (disregarded payments), (c) (deemed branch payments), and (e) (branch mismatch transactions), 1.267A-4 (imported mismatch rule), and 1.267A-5(b)(5) (structured payments), except as provided in of this section, apply to taxable years beginning on or after December 20, 2018.
(2) Section (defining structured arrangement), as well as the portions of through that relate to structured arrangements and that are not otherwise described in of this section, apply to taxable years beginning on or after December 20, 2018. However, in the case of a specified payment made pursuant to an arrangement entered into before December 22, 2017, , and the portions of through that relate to structured arrangements and that are not otherwise described in of this section, apply to taxable years beginning after December 31, 2020.
(3) Except as provided in of this section, the rules provided in (swaps with significant nonperiodic payments) apply to notional principal contracts entered into on or after April 8, 2021. However, taxpayers may apply the rules provided in to notional principal contracts entered into before April 8, 2021.
(4) For a notional principal contract entered into before April 8, 2021, the interest equivalent rules provided in (applied without regard to the references to ) apply to a notional principal contract entered into on or after April 8, 2020.
(5) Section (interest equivalent rules) applies to transactions entered into on or after April 8, 2020.
[T.D. 9896, 85 FR 19836, Apr. 8, 2020, as amended by 85 FR 48651, Aug. 12, 2020]