SECTION 4. APPLICABILITY

DATE

It is expected that the forthcoming regulations will apply to taxable years of United States shareholders (and successors in interest) ending after December 14, 2018, and to taxable years of foreign corporations ending with or within such taxable years of United States shareholders. See section 7805(b)(1)(C). Before the issuance of the forthcoming regulations, a shareholder may rely on the rules described in section 3 of this notice if the shareholder and each person related to the shareholder under section 267(b) or 707(b) (each such person, a “related shareholder”) apply the rules consistently with respect to PTEP of all foreign corporations in which the shareholder or related shareholder, as the case may be, owns stock for all taxable years beginning with the shareholder’s or the related shareholder’s taxable year that includes the taxable year end of any such foreign corporation to which section 965 applies.