SECTION 6. EFFECTIVE DATES

The regulations described in sections 4.01 through 4.06(1), 4.07, and 4.08 of this notice will apply to transfers occurring on or after August 6, 2015, and to transfers occurring before August 6, 2015, resulting from entity classification elections made under § 301.7701–3 that are filed on or after August 6, 2015, and that are effective on or before August 6, 2015. The reporting requirements described in section 4.06(2) and (3) of this notice and the regulations described in section 5 of this notice will apply to transfers and controlled transactions occurring on or after the date of publication of the regulations described in those sections.

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, Treasury regulations, and judicial doctrines. For example, the IRS may challenge a partnership’s adopted section 704(c) method (for purposes of § 1.704–3(a)(1)) under the anti-abuse rule in § 1.704–3(a)(10).