SECTION 4. EFFECTIVE DATES

Except as provided in this section 4, the regulations described in (i) section 2.01(b) of this notice (which disregards certain stock of the foreign acquiring corporation attributable to passive assets) will apply to acquisitions completed on or after September 22, 2014; (ii) section 2.02(b) of this notice (which disregards certain distributions by a domestic entity) will apply to acquisitions, or to transfers of domestic stock described in § 1.367(a)– 3(c), completed on or after September 22, 2014; (iii) section 2.03(b) of this notice (regarding the application of the EAG rules upon a subsequent transfer of stock of the foreign acquiring corporation) will apply to acquisitions completed on or after September 22, 2014; (iv) section 3.01(b) of this notice will apply to acquisitions of obligations or stock of a nonCFC foreign related person by an expatriated foreign subsidiary completed on or after September 22, 2014, but only if the inversion transaction is completed on or after September 22, 2014; (v) section 3.02(e) of this notice will apply to specified transactions and specified exchanges completed on or after September 22, 2014, but only if the inversion transaction is completed on or after September 22,

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2014; and (vi) section 3.03(b) of this notice will apply to acquisitions of stock described in section 304 completed on or after September 22, 2014.

Taxpayers may elect to apply the rule in section 2.03(b)(iii) of this notice (regarding subsequent transfers of stock of the foreign acquiring corporation when a domestic entity is a member of a foreignparented group) to acquisitions completed before September 22, 2014.

No inference is intended regarding 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.