SECTION 4. RELIEF IN

CONNECTION WITH HURRICANE FLORENCE

On September 15, 2018, and September 24, 2018, in response to Hurricane Florence, the IRS announced (IR–2018– 187, NC–2018–03, SC–2018–01) that certain individual and business taxpayers would have until January 31, 2019, to file certain tax returns and make certain tax payments. Questions have arisen as to whether that announcement applies to elections with respect to section 965 and transfer agreements required to be filed under the proposed regulations. This notice provides a postponement for affected taxpayers to make elections with respect to section 965 and file transfer agreements required to be filed under the proposed regulations. Affected taxpayers for whom elections with respect to section 965 or transfer agreements are due on or after September 7, 2018, and before January 31, 2019, are granted additional time to file such elections or transfer agreements until January 31, 2019.

An affected taxpayer is any taxpayer whose principal residence or principal place of business was located in a Hurricane Florence covered disaster area, as

defined in § 301.7508A–1(d)(2), or whose records necessary to meet its obligation were maintained in such a covered disaster area, or in the case of a transfer agreement, a taxpayer who intends to enter into a transfer agreement with such a taxpayer.

Taxpayers who believe they are entitled to this relief should mark “Hurricane Florence” on the top of the relevant section 965 election statement or transfer agreement, and, in the case of a transfer agreement, a notation of which party to the agreement is an affected taxpayer whose principal residence or principal place of business was located in a Hurricane Florence covered disaster area, as defined in § 301.7508A– 1(d)(2), or whose records necessary to meet its filing obligation were maintained in such a covered disaster area.