Sections 1.1446-1 through 1.1446-5 shall apply to partnership taxable years beginning after May 18, 2005. However, a partnership may elect to apply all of the provisions of Secs. 1.1446-1 through 1.1446-5 to partnership taxable years beginning after December 31, 2004. A partnership shall make the election under this section by complying with the provisions of Secs. 1.1446-1 through Sec. 1.1446-5 and attaching a statement to the Form 8804 or Form 1042 annual return, filed for the taxable year in which the regulation provisions first apply, that indicates that the partnership is making the election under this section. The revisions to Secs. 1.1446-3(b)(2), 1.1446-3(b)(3)(i)(A) and 1.1446-5(c)(2) contained in the final regulations published in 2008 apply to partnership taxable years beginning after December 31, 2007. See Sec. 1.1446-6(f) and (g) for the Effective/Applicability date and Transition rule for Sec. 1.1446-6. [T.D. 9200, 70 FR 28717, May 18, 2005, as amended by T.D. 9394, 73 FR 23085, Apr. 29, 2008]
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