Current through October 31, 2024
Section 1.679-7 - Effective dates(a)In general. Except as provided in paragraph (b) of this section, the rules of §§ 1.679-1 , 1.679-2 , 1.679-3 , and 1.679-4 apply with respect to transfers after August 7, 2000.(b)Special rules.(1) The rules of § 1.679-4(c) and (d) apply to an obligation issued after February 6, 1995, whether or not in accordance with a pre-existing arrangement or understanding. For purposes of the rules of § 1.679-4(c) and (d) , if an obligation issued on or before February 6, 1995, is modified after that date, and the modification is a significant modification within the meaning of § 1.1001-3 , the obligation is treated as if it were issued on the date of the modification. However, the penalty provided in section 6677 applies only to a failure to report transfers in exchange for obligations issued after August 20, 1996.(2) The rules of § 1.679-5 apply to persons whose residency starting date is after August 7, 2000.(3) The rules of § 1.679-6 apply to trusts that become foreign trusts after August 7, 2000.T.D. 8955, 66 FR 37889 , July 20, 2001