SECTION 6. EFFECTIVE DATE

The future regulations described in this notice will be effective beginning on or after May 2, 2006. Until those regulations are issued, taxpayers may rely upon the provisions of this notice as of May 2, 2006. In addition, taxpayers may elect to apply sections 3 and 4 of this notice retroactively to tax years of foreign corporations beginning after December 31, 2004, and for tax years of United States shareholders with or within which such tax years of foreign corporations end. Taxpayers may elect to apply section 5 of this notice retroactively to transfers of aircraft or vessels occurring on or after October 22, 2004. This election is made by providing the description of the transfer under § 1.6038B–1T(c) as specified in section 5.01 of this notice. No relief under § 301.9100–1 is necessary for this election. Taxpayers electing to apply sections 3 through 5 of this notice retroactively must do so consistently for all transactions.