Sections 1.468A-1 through 1.468A-8 are effective on December 23, 2010 and apply with respect to taxable years ending after such date. Special rules that are provided for taxable years ending on or before such date, such as the special rule for certain special transfers contained in §1.468A-8(a)(4)(ii), apply with respect to such taxable years. In addition, a taxpayer may apply the provisions of §§1.468A-1 through 1.468A-8 with respect to a taxable year ending on or before December 23, 2010 if all such provisions are consistently applied.

[T.D. 9512, 75 FR 80701, Dec. 23, 2010]