SECTION 5. APPLICABILITY DATES

AND RELIANCE

The forthcoming proposed regulations incorporating the guidance described in sections 3 and 4 of this notice will apply to distributions, transfers, or exchanges occurring on or after August 19, 2025. Taxpayers may rely on the rules described in section 3 of this notice for covered inbound F reorganizations occurring before the forthcoming proposed regulations are published in the Federal Register, provided taxpayers follow those rules in their entirety and in a consistent manner. Taxpayers also may rely on the rules described in section 4 of this notice for potential F reorganizations before the forthcoming proposed regulations are published in the Federal Register.