26 C.F.R. § 1.1367-3

Effective/Applicability date

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Section 1.1367-2(a), (c)(2), (d)(2), and (e) Example 6, Example 7, and Example 8 apply to any shareholder advances to the S corporation made on or after October 20, 2008 and repayments on those advances by the S corporation. The rules that apply with respect to shareholder advances to the S corporation made before October 20, 2008, are contained in § 1.1367-3 in effect prior to October 20, 2008. (See 26 CFR part 1 revised as of April 1, 2007.) Shareholders have the option to apply these rules to shareholder advances to the S corporation made before October 20, 2008, and repayments on those advances by the S corporation. Section 1.1367-1(h), Example 5(iii) applies on and after July 23, 2014. The rules that apply before July 23, 2014 are contained in § 1.1367-3 in effect prior to July 23, 2014 (see 26 CFR part 1 revised as of April 1, 2014).

[T.D. 9428, 73 FR 62203, Oct. 20, 2008, as amended by T.D. 9682, 79 FR 42678, July 23, 2014]

Notes of Decisions

Cited in 1 case, 2000–2000 · leading case: Briggs v. Comm'r, 2000 T.C. Memo. 380 (Tax Ct. 2000).

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Briggs v. Comm'r, 2000 T.C. Memo. 380 (Tax Ct. 2000). · cites it 4× “For the years in issue, the regulations provide that adjustments to the basis of a shareholder's stock and to the basis of indebtedness of an S corporation to a shareholder "must be determined in a reasonable manner, taking into account the statute and the legislative history.”

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