Code of Federal Regulations Title 26. Internal Revenue § 26.1.679–7 Effective dates

(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.