Treasury Regulations, Subchapter B, Sec. 25.2519-2
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Sec. 25.2519-2 Effective date
Except as specifically provided in §25.2519–1(g), Example 6, the provisions of §25.2519–1 are effective with respect to gifts made after March 1, 1994. With respect to gifts made on or before such date, the donee spouse of a section 2056(b)(7) or section 2523(f) transfer may rely on any reasonable interpretation of the statutory provisions. For these purposes, the provisions of §25.2519–1 (as well as project LR–211–76, 1984–1 C.B., page 598, see §601.601(d)(2)(ii)(b) of this chapter), are considered a reasonable interpretation of the statutory provisions.
[T.D. 8522, 59 FR 9658, Mar. 1, 1994]
