(a) General rule. —(1) Taxable years starting before January 1, 2011, taxable events taking place or property transfers made before January 1, 2011. — Final agreements to be executed by the Secretary after December 31, 2010, in connection with matters related to taxable years starting before January 1, 2011, or taxable events taking place, or property transfers made before January 1, 2011, shall be governed by the corresponding provisions of the Puerto Rico Internal Revenue Code of 1994.(2) Taxable years starting after December 31, 2010, taxable events taking place or property transfers made after December 31, 2010. — Final agreements to be executed by the Secretary in connection with matters related to taxable years starting after December 31, 2010, or taxable events taking place, or property transfers made after December 31, 2010, shall be governed by the provisions of this Code. History —Jan. 31, 2011, No. 1, § 6091.06, retroactive to Jan. 1, 2011.