26 CFR § 1.951A-7
Applicability dates
June 25, 2020
Sections 1.951A-1 through 1.951A-6 apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.
[T.D. 9866, 84 FR 29341, June 21, 2019]