(a) In general. Sections 1.846-1 through 1.846-3 apply to taxable years beginning after December 31, 1986.
(b) Section 338 election. Section 1.846-2(d) applies to section 846(e) elections made with regard to a qualified stock purchase made on or after April 10, 2006. [T.D. 9257, 71 FR 18006, Apr. 10, 2006, as amended by T.D. 9377, 73 FR 3873, Jan. 23, 2008] Sec. 1.846-4T Effective dates (temporary).
(a) [Reserved]. For further guidance, see Sec. 1.846-2(a).
(b) Section 338 election. Section 1.846-2(d) applies to section 846(e) elections made with regard to a qualified stock purchase made on or after April 10, 2006. [T.D. 9257, 71 FR 18006, Apr. 10, 2006]