Sections 970 through 972 and Secs. 1.970-1 through 1.972-1 shall apply with respect to taxable years of foreign corporations beginning after December 31, 1962, and to taxable years of United States shareholders within which or with which such taxable years of such corporations end. [T.D. 6755, 29 FR 12709, Sept. 9, 1964]