26 CFR · Internal Revenue
§ 1.245A-11 — Applicability dates.
26 CFR § 1.245A-11
This text of 26 C.F.R. § 1.245A-11 (Applicability dates.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Bluebook
26 C.F.R. § 1.245A-11 (2026).
Text
§ 1.245A-11 Applicability dates.
(a)In general. Sections 1.245A-6 through 1.245A-11 apply to taxable years of a foreign corporation beginning on or after December 1, 2020 and to taxable years of section 245A shareholders in which or with which such taxable years end.
(b)Exception. Notwithstanding paragraph (a) of this section, a taxpayer may choose to apply §§ 1.245A-6 through 1.245A-11 for a taxable year of a foreign corporation beginning before December 1, 2020 and to a taxable year of a section 245A shareholder in which or with which such taxable year ends, provided that the taxpayer and all persons bearing a relationship to the taxpayer described in section 267(b) or 707(b) apply §§ 1.245A-6 through 1.245A-11, in their entirety, and § 1.6038-2(f)(18) for all such taxable years and a
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Related
§ 1.245
26 C.F.R. § 1.245
§ 1.6038-2
26 C.F.R. § 1.6038-2
Nearby Sections
11
§ 1.245A-7
Coordination rules for simple cases.§ 1.245A-8
Coordination rules for complex cases.§ 1.245A-9
Other rules and definitions.§ 1.245A-10
Examples.§ 1.245A-11
Applicability dates.§ 1.245A(d)-1
Disallowance of foreign tax credit or deduction.§ 1.245A(e)-1
Special rules for hybrid dividends.§ 1.246-3
Exclusion of certain dividends.Cite This Page — Counsel Stack
Bluebook (online)
26 C.F.R. § 1.245A-11, Counsel Stack Legal Research, https://law.counselstack.com/cfr/26/1/1.245A-11.