SECTION 7. APPLICABILITY

DATES

It is anticipated that the forthcoming proposed regulations will provide that rules consistent with the guidance provided in sections 3 through 6 of this notice will apply for taxable years beginning on or after the date final regulations addressing §§ 56A(c)(2)(B), 56A(c)(2) (C), 56A(c)(15)(B), and 56A(e) are published in the Federal Register . For tax

able years beginning before the date on which forthcoming proposed regulations are published in the Federal Register, or other guidance modifying this section 7 is published in the Internal Revenue Bulletin, taxpayers may rely on the guidance provided in sections 3 through 6 of this notice, including for purposes of filing amended returns. A taxpayer’s reliance on any of the guidance provided in sections 3 through 6 of this notice for a taxable year will not cause the corporation to become subject to, or to violate, the reliance rules, including the consistency requirements, provided in the preamble of the CAMT Proposed Regulations for such taxable year.