26 C.F.R. § 1.1366-5

Effective/applicability date

Read at: eCFRecfr.gov CornellLII GovInfogovinfo.gov CasesGoogle Scholar

(a) Sections 1.1366-1, 1.1366-2(a)(1), and 1.1366-2(b) through 1.1366-4 apply to taxable years of an S corporation beginning on or after August 18, 1998.

(b) Section 1.1366-2(a)(2) applies to indebtedness between an S corporation and its shareholder resulting from any transaction occurring on or after July 23, 2014. In addition, S corporations and their shareholders may rely on § 1.1366-2(a)(2) with respect to indebtedness between an S corporation and its shareholder that resulted from any transaction that occurred in a year for which the period of limitations on the assessment of tax has not expired before July 23, 2014.

(c) Sections 1.1366-2(a)(3) through (7), and this section apply on and after July 23, 2014. For rules that apply before that date, see 26 CFR part 1 (revised as of April 1, 2014).

[ T.D. 9682, 79 FR 42678, July 23, 2014]

Notes of Decisions

Cited in 1 case, 2017–2017 · leading case: Phillips v. Comm'r, 2017 T.C. Memo. 61 (Tax Ct. 2017).

Sort: Relevance Newest Treatment

Phillips v. Comm'r, 2017 T.C. Memo. 61 (Tax Ct. 2017). · cites it 2× “These regulations apply to transactions occurring after their issuance, though taxpayers may elect to apply them to any open tax year.”

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.