SECTION 4. EFFECTIVE/

APPLICABILITY DATE

This notice applies to taxable years beginning in or after 2020. Until further guidance is issued, taxpayers may rely on the interim guidance described in this notice.

Pursuant to Section IV. of the Policy Statement on the Tax Regulatory Process issued by the Treasury Department and the IRS on March 5, 2019, if no proposed regulations or other guidance is released within 18 months after September 28, 2020, taxpayers may continue to rely on the interim guidance described in this notice but, until additional guidance is issued, the Treasury Department and the IRS will not assert a position adverse to any taxpayer, including an applicable large employer under section 4980H, based in whole or in part on this notice.