Section 1.684-5 - Effective/applicability dates(a) Sections 1.684-1 through 1.684-4 apply to transfers of property to foreign trusts and foreign estates after August 7, 2000, except as provided in paragraph (b) of this section.(b) In the case a U.S. transferor decedent dying in 2010, § 1.684-3(c) applies to transfers of property to foreign trusts, foreign estates, and nonresident aliens after December 31, 2009, and before January 1, 2011.T.D. 9811, 82 FR 6239 , Jan. 19, 2017 T.D. 9811, 82 FR 6239 , 1/19/2017