SECTION 5. EFFECTIVE DATE
Internal Revenue Bulletin 2012-31 · 2026-10-03 edition · updated 2026-10-04 · United States
The regulations described in this notice will apply to outbound section 367(d) transfers occurring on or after July 13, 2012. No inference is intended as to the treatment of transactions described in this notice under current law, and the IRS may challenge such transactions under applicable Code provisions or judicial doctrines.
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