[Code of Federal Regulations]
[Title 26, Volume 2]
[Revised as of April 1, 2003]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.148-11A]
[Page 736-737]
TITLE 26--INTERNAL REVENUE
CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
(CONTINUED)
PART 1--INCOME TAXES--Table of Contents
Sec. 1.148-11A Effective dates.
(a) through (c)(3) [Reserved]. For guidance see Sec. 1.148-11.
(c)(4) Retroactive application of overpayment recovery provisions.
An issuer may apply the provisions of Sec. 1.148-3(i) to any issue that
is subject to section 148(f) or to sections 103(c)(6) or 103A(i) of the
Internal Revenue Code of 1954.
(d) through (h) [Reserved]. For guidance see Sec. 1.148-11.
(i) Transition rules for certain amendments--(1) In general. Section
1.103-8(a)(5), Secs. 1.148-1, 1.148-2, 1.148-3, 1.148-4, .148-5, 1.148-
6, 1.148-7, 1.148-8, 1.148-9, 1.148-10, 1.148-11, 1.149(d)-1, and 1.150-
1 as in effect on June 7, 1994 (see 26 CFR part 1 as revised April 1,
1997), and Secs. 1.148-1A through 1.148-11A, 1.149(d)-1A, and 1.150-1A
apply, in whole, but not in part--
(i) To bonds sold after June 6, 1994, and before July 8, 1997;
(ii) To bonds issued before July 1, 1993, that are outstanding on
June 7, 1994, if the first time the issuer applies Secs. 1.148-1 through
1.148-11 as in effect on June 7, 1994 (see 26 CFR part 1 as revised
April 1, 1997), to the bonds under Sec. 1.148-11 (b) or (c) is after
June 6, 1994, and before July 8, 1997;
(iii) At the option of the issuer, to bonds to which Secs. 1.148-1
through 1.148-11, as in effect on July 1, 1993 (see 26 CFR part 1 as
revised April 1, 1994), apply, if the bonds are outstanding on June 7,
1994, and the issuer applies Sec. 1.103-8(a)(5), Secs. 1.148-1, 1.148-2,
1.148-3, 1.148-4, 1.148-5, 1.148-6, 1.148-7, 1.148-8, 1.148-9, 1.148-10,
1.148-11, 1.149(d)-1, and 1.150-1 as in effect on June 7, 1994 (see 26
CFR part 1 as revised April 1, 1997), and Secs. 1.148-1A through 1.148-
11A, 1.149(d)-1A, and 1.150-1A to the bonds before July 8, 1997.
[[Page 737]]
(2) Special rule. For purposes of paragraph (i)(1) of this section,
any reference to a particular paragraph of Secs. 1.148-1T, 1.148-2T,
1.148-3T, 1.148-4T, 1.148-5T, 1.148-6T, 1.148-9T, 1.148-10T, 1.148-11T,
1.149(d)-1T, or 1.150-1T shall be applied as a reference to the
corresponding paragraph of Secs. 1.148-1A, 1.148-2A, 1.148-3A, 1.148-4A,
1.148-5A, 1.148-6A, 1.148-9A, 1.148-10A, 1.148-11A, 1.149(d)-1A, or
1.150-1A, respectively.
(3) Identification of certain hedges. For any hedge entered into
after June 18, 1993, and on or before June 6, 1994, that would be a
qualified hedge within the meaning of Sec. 1.148-4(h)(2), as in effect
on June 7, 1994 (see 26 CFR part 1 as revised April 1, 1997), except
that the hedge does not meet the requirements of Sec. 1.148-4A(h)(2)(ix)
because the issuer failed to identify the hedge not later than 3 days
after which the issuer and the provider entered into the contract, the
requirements of Sec. 1.148-4A(h)(2)(ix) are treated as met if the
contract is identified by the actual issuer on its books and records
maintained for the hedged bonds not later than July 8, 1997.
[T.D. 8538, 59 FR 24046, May 10, 1994. Redesignated and amended by T.D.
8718, 62 FR 25507, 25513, May 9, 1997]