SECTION 11. APPLICABILITY DATES

AND RELIANCE

.01 Applicability dates . It is anticipated that the forthcoming proposed regulations will propose rules consistent with the guidance described in sections 3 through 10 of this notice that will apply for taxable years beginning on or after the date the final regulation addressing the AFSI adjustment or other modification to the CAMT Proposed Regulations described in

a respective section of this notice is published in the Federal Register .

.02 Reliance . (1) In general . Subject to section 11.02(2), (3), and (4) of this notice, for all taxable years beginning before the date such forthcoming proposed regulations are published in the Federal Reg- ister, taxpayers may rely on the guidance in this notice. In addition, reliance on section 3, 4, 5, 6 or 7 of this notice is conditioned on the taxpayer meeting the consistency requirement set forth in that section. A taxpayer’s reliance on any of the guidance in this notice for a taxable year will not cause the taxpayer to become subject to, or to violate, the proposed reliance rules, including the consistency requirements, provided in section 3.02(1) of Notice 2025-49 for such taxable year.

(2) Sections 9 and 10 of this notice . (a) A taxpayer that relies on proposed § 1.56A-4 may rely on section 9 of this notice for taxable years beginning before the date the forthcoming proposed regulations are published in the Federal Register, provided that the requirements described in section 3.02(1)(b) of Notice 2025-49 are satisfied for all such taxable years beginning with the first taxable year with respect to which the taxpayer relies on section 9 of this notice.

(b) A taxpayer that relies on proposed § 1.56A-4 may rely on section 10 of this notice for taxable years beginning before the date the forthcoming proposed regulations are published in the Federal Register, provided that the requirements described in section 3.02(1)(b) of Notice 2025-49 are satisfied for all such taxable years beginning with the first taxable year with respect to which the taxpayer relies on section 10 of this notice. A taxpayer that does not rely on section 10 of this notice may continue to rely on proposed §§ 1.56A-4 or 1.56A-6, as applicable, subject to the requirements of section 3.02(1) of Notice 2025-49.

(3) Section 4 of Notice 2025-49 . As an alternative to relying on section 4 of Notice 2025-49 as modified by section 3 of this notice for all taxable years beginning before the date the forthcoming proposed regulations are published in the Federal Register, a taxpayer may instead choose to rely on section 4 of