Treasury Regulations (26 C.F.R.)
26 CFR § 1.267A-7
Applicability dates.
# (a) General rule.
Except as provided in paragraph (b) of this section, §§ 1.267A-1 through 1.267A-6 apply to taxable years ending on or after December 20, 2018, provided that such taxable years begin after December 31, 2017. However, taxpayers may apply the regulations in §§ 1.267A-1 through 1.267A-6 in their entirety (including by taking into account paragraph (b) of this section) for taxable years beginning after December 31, 2017, and ending before December 20, 2018. In lieu of applying the regulations in §§ 1.267A-1 through 1.267A-6 (including paragraph (b) of this section), taxpayers may apply the provisions matching §§ 1.267A-1 through 1.267A-6 (including by taking into account the provision matching paragraph (b) of this section) from the Internal Revenue Bulletin (IRB) 2019-03 (https://www.irs.gov/pub/irs-irbs/irb19-03.pdf) in their entirety for all taxable years ending on or before April 8, 2020.
# (b) Special rules.
The following special rules apply regarding applicability dates:
(1) Sections 1.267A-2(a)(4) (payments pursuant to interest-free loans and similar arrangements), (b) (disregarded payments), (c) (deemed branch payments), and (e) (branch mismatch transactions), 1.267A-4 (imported mismatch rule), and 1.267A-5(b)(5) (structured payments), except as provided in paragraph (b)(5) of this section, apply to taxable years beginning on or after December 20, 2018.
(2) Section 1.267A-5(a)(20) (defining structured arrangement), as well as the portions of §§ 1.267A-1 through 1.267A-3 that relate to structured arrangements and that are not otherwise described in paragraph (b) of this section, apply to taxable years beginning on or after December 20, 2018. However, in the case of a specified payment made pursuant to an arrangement entered into before December 22, 2017, § 1.267A-5(a)(20), and the portions of §§ 1.267A-1 through 1.267A-3 that relate to structured arrangements and that are not otherwise described in paragraph (b) of this section, apply to taxable years beginning after December 31, 2020.
(3) Except as provided in paragraph (b)(4) of this section, the rules provided in § 1.267A-5(a)(12)(ii) (swaps with significant nonperiodic payments) apply to notional principal contracts entered into on or after April 8, 2021. However, taxpayers may apply the rules provided in § 1.267A-5(a)(12)(ii) to notional principal contracts entered into before April 8, 2021.
(4) For a notional principal contract entered into before April 8, 2021, the interest equivalent rules provided in § 1.267A-5(b)(5)(ii)(B) (applied without regard to the references to § 1.267A-5(a)(12)(ii)) apply to a notional principal contract entered into on or after April 8, 2020.
(5) Section 1.267A-5(b)(5)(ii)(B) (interest equivalent rules) applies to transactions entered into on or after April 8, 2020.
[T.D. 9896, 85 FR 19836, Apr. 8, 2020, as amended by 85 FR 48651, Aug. 12, 2020]
Source: view the official text
In this part (40 sections)
- 1.263A-10 · Unit of property.
- 1.263A-11 · Accumulated production expenditures.
- 1.263A-12 · Production period.
- 1.263A-13 · Oil and gas activities.
- 1.263A-14 · Rules for related persons.
- 1.263A-15 · Effective dates, transitional rules, and anti-abuse rule.
- 1.264-1 · Premiums on life insurance taken out in a trade or business.
- 1.264-2 · Single premium life insurance, endowment, or annuity…
- 1.264-3 · Effective date; taxable years ending after March 1, 1954,…
- 1.264-4 · Other life insurance, endowment, or annuity contracts.
- 1.265-1 · Expenses relating to tax-exempt income.
- 1.265-2 · Interest relating to tax exempt income.
- 1.265-3 · Nondeductibility of interest relating to exempt-interest…
- 1.266-1 · Taxes and carrying charges chargeable to capital account and…
- 1.267A-1 · Disallowance of certain interest and royalty deductions.
- 1.267A-2 · Hybrid and branch arrangements.
- 1.267A-3 · Income inclusions and amounts not treated as disqualified…
- 1.267A-4 · Disqualified imported mismatch amounts.
- 1.267A-5 · Definitions and special rules.
- 1.267A-6 · Examples.
- 1.267A-7 · Applicability dates.
- 1.267(a)-1 · (a)-1 Deductions disallowed.
- 1.267(a)-2T · (a)-2T Temporary regulations; questions and answers…
- 1.267(a)-3 · (a)-3 Deduction of amounts owed to related foreign persons.
- 1.267(b)-1 · (b)-1 Relationships.
- 1.267(c)-1 · (c)-1 Constructive ownership of stock.
- 1.267(d)-1 · (d)-1 Amount of gain where loss previously disallowed.
- 1.267(d)-2 · (d)-2 Effective/applicability dates.
- 1.267(f)-1 · (f)-1 Controlled groups.
- 1.268-1 · Items attributable to an unharvested crop sold with the land.
- 1.269-1 · Meaning and use of terms.
- 1.269-2 · Purpose and scope of section 269.
- 1.269-3 · Instances in which section 269(a) disallows a deduction,…
- 1.269-4 · Power of district director to allocate deduction, credit, or…
- 1.269-5 · Time of acquisition of control.
- 1.269-6 · Relationship of section 269 to section 382 before the Tax…
- 1.269-7 · Relationship of section 269 to sections 382 and 383 after the…
- 1.269B-1 · Stapled foreign corporations.
- 1.270-1 · Limitation on deductions allowable to individuals in certain…
- 1.271-1 · Debts owed by political parties.