Sections 1.960-1 through 1.960-6 apply to each taxable year of a foreign corporation that both begin after December 31, 2017, and ends on or after December 4, 2018, and to each taxable year of a domestic corporation that is a United States shareholder of the foreign corporation in which or with which such taxable year of such foreign corporation ends.

[T.D. 9882, 84 FR 69120, Dec. 17, 2019]