SECTION 11. TRANSITION RULES

.01 Domestic Reinvestment Plans Approved Prior to August 19, 2005

If a domestic reinvestment plan is approved prior to August 19, 2005, the taxpayer may modify such plan to take into account the guidance herein not later than October 19, 2005, even if the dividend to which the domestic reinvestment plan relates has already been paid. Any plan that is so modified must be subsequently approved by the taxpayer’s president, chief executive officer, or comparable official and by the taxpayer’s board of directors, management committee, executive committee, or similar body.

.02 Tax Returns Filed Prior to August 19, 2005

If, prior to August 19, 2005, a taxpayer has filed its tax return for the taxable year to which it elects section 965 to apply, such taxpayer may revise its computations or annual reporting to conform to the guidance in this notice on an amended tax return that is filed by December 31, 2005.