[Code of Federal Regulations] [Title 26, Volume 2] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.148-11A] [Page 760] 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), Sec. Sec. 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 Sec. Sec. 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 Sec. Sec. 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 Sec. Sec. 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), Sec. Sec. 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 Sec. Sec. 1.148-1A through 1.148-11A, 1.149(d)-1A, and 1.150-1A to the bonds before July 8, 1997. (2) Special rule. For purposes of paragraph (i)(1) of this section, any reference to a particular paragraph of Sec. Sec. 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 Sec. Sec. 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]