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Introduction

SECTION 5. EFFECTIVE DATE

Internal Revenue Bulletin 2016-52 · 2026-10-03 edition · updated 2026-10-04 · United States

The regulations described in Section 4 of this notice will apply to transactions completed on or after December 2, 2016, and to any inbound transactions treated as completed before December 2, 2016 as a result of an entity classification election made under § 301.7701–3 of this chapter that is filed on or after December 2, 2016 . No inference is intended regarding the treatment of transactions described in Section 3 of this notice under current law. For example, these transactions are currently subject to challenge under the anti-abuse rule.

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▸Contents — Internal Revenue Bulletin 2016-52

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