Treasury Regulations (26 C.F.R.)
26 CFR § 53.4965-9
Effective/applicability dates.
# (a) In general.
The taxes under section 4965(a) and § 53.4965-7 are effective for taxable years ending after May 17, 2006, with respect to transactions entered into before, on or after that date, except that no tax under section 4965(a) applies with respect to income or proceeds that are properly allocable to any period ending on or before August 15, 2006.
# (b) Applicability of the regulations.
As of July 6, 2010, except as provided in paragraph (c) of this section, §§ 53.4965-1 through 53.4965-8 of this chapter will apply to taxable years ending after July 6, 2007. A tax-exempt entity may rely on the provisions of §§ 53.4965-1 through 53.4965-8 for taxable years ending on or before July 6, 2007.
# (c)
Effective/applicability date with respect to certain knowing transactions—(1) Entity-level tax. The 100 percent tax under section 4965(b)(1)(B) and § 53.4965-7(a)(1)(i)(B) does not apply to prohibited tax shelter transactions entered into by a tax-exempt entity on or before May 17, 2006.
(2) Manager-level tax. The IRS will not assert that an entity manager who approved or caused a tax-exempt entity to become a party to a prohibited tax shelter transaction is liable for the entity manager tax under section 4965(b)(2) and § 53.4965-7(b)(1) with respect to the transaction if the tax-exempt entity entered into such transaction prior to May 17, 2006.
[T.D. 9492, 75 FR 38702, July 6, 2010]
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In this part (40 sections)
- 53.4958-8 · Special rules.
- 53.4959-1 · Taxes on failures by hospital organizations to meet section…
- 53.4960-0 · Table of contents.
- 53.4960-1 · Scope and definitions.
- 53.4960-2 · Determination of remuneration paid for a taxable year.
- 53.4960-3 · Determination of whether there is a parachute payment.
- 53.4960-4 · Liability for tax on excess remuneration and excess…
- 53.4960-5 · [Reserved]
- 53.4960-6 · Applicability date.
- 53.4961-1 · Abatement of second tier taxes for correction within…
- 53.4961-2 · Court proceedings to determine liability for second tier…
- 53.4963-1 · Definitions.
- 53.4965-1 · Overview.
- 53.4965-2 · Covered tax-exempt entities.
- 53.4965-3 · Prohibited tax shelter transactions.
- 53.4965-4 · Definition of tax-exempt party to a prohibited tax shelter…
- 53.4965-5 · Entity managers and related definitions.
- 53.4965-6 · Meaning of “knows or has reason to know”.
- 53.4965-7 · Taxes on prohibited tax shelter transactions.
- 53.4965-8 · Definition of net income and proceeds and standard for…
- 53.4965-9 · Effective/applicability dates.
- 53.4968-1 · Excise tax based on investment income of certain private…
- 53.4968-2 · Net investment income.
- 53.4968-3 · Related organizations.
- 53.4968-4 · Applicability date.
- 53.6001-1 · Notice or regulations requiring records, statements, and…
- 53.6011-1 · General requirement of return, statement or list.
- 53.6011-4 · Requirement of statement disclosing participation in…
- 53.6060-1 · Reporting requirements for tax return preparers.
- 53.6061-1 · Signing of returns and other documents.
- 53.6065-1 · Verification of returns.
- 53.6071-1 · Time for filing returns.
- 53.6081-1 · Automatic extension of time for filing the return to report…
- 53.6091-1 · Place for filing chapter 42 tax returns.
- 53.6091-2 · Exceptional cases.
- 53.6107-1 · Tax return preparer must furnish copy of return or claim…
- 53.6109-1 · Tax return preparers furnishing identifying numbers for…
- 53.6151-1 · Time and place for paying tax shown on returns.
- 53.6161-1 · Extension of time for paying tax or deficiency.
- 53.6165-1 · Bonds where time to pay tax or deficiency has been extended.