Section 1.684-5 - Effective/applicability dates(a) Sections 1.684-1 through 1.684-4 apply to transfers of property to foreign trusts and foreign estates after August 7, 2000, except as provided in paragraph (b) of this section.(b) In the case a U.S. transferor decedent dying in 2010, § 1.684-3(c) applies to transfers of property to foreign trusts, foreign estates, and nonresident aliens after December 31, 2009, and before January 1, 2011.T.D. 9811, 82 FR 6239, Jan. 19, 2017 T.D. 9811, 82 FR 6239, 1/19/2017