![]() |
Code of Federal Regulations (Last Updated: July 5, 2024) |
![]() |
Title 26 - Internal Revenue |
![]() |
Chapter I - Internal Revenue Service, Department of the Treasury |
![]() |
SubChapter A - Income Tax |
![]() |
Part 1 - Income Taxes |
![]() |
rantors and others treated as substantial owners |
§ 1.679-7 - Effective dates.
-
§ 1.679-7 Effective dates.
(a) In general. Except as provided in paragraph (b) of this section, the rules of §§ 1.679-1, 1.679-2, 1.679-3, and 1.679-4 apply with respect to transfers after August 7, 2000.
(b) Special rules.
(1) The rules of § 1.679-4(c) and (d) apply to an obligation issued after February 6, 1995, whether or not in accordance with a pre-existing arrangement or understanding. For purposes of the rules of § 1.679-4(c) and (d), if an obligation issued on or before February 6, 1995, is modified after that date, and the modification is a significant modification within the meaning of § 1.1001-3, the obligation is treated as if it were issued on the date of the modification. However, the penalty provided in section 6677 applies only to a failure to report transfers in exchange for obligations issued after August 20, 1996.
(2) The rules of § 1.679-5 apply to persons whose residency starting date is after August 7, 2000.
(3) The rules of § 1.679-6 apply to trusts that become foreign trusts after August 7, 2000.
[T.D. 8955, 66 FR 37889, July 20, 2001]