Section 36.3121(l)(5)-1 - Effect of termination(a)Termination of entire agreement.(1) If the effective period of an agreement entered into by a domestic corporation as provided in § 36.3121(l)(1) -1 is terminated by the domestic corporation, pursuant to § 36.3121(l)(3) -1(a), with respect to all foreign subsidiaries named in the agreement, including any amendment thereof, an agreement may not again be entered into by the domestic corporation under the provisions of section 3121(l)(1).(2) If the effective period of an agreement entered into by a domestic corporation as provided in § 36.3121(l)(1) -1 is terminated by the Commissioner, pursuant to § 36.3121(l)(4) -1 (a), an agreement may not again be entered into by the domestic corporation under the provisions of section 3121(l)(1).(3) If the effective period of an agreement entered into by a domestic corporation as provided in § 36.3121(l)(1) -1 is terminated automatically by reason of a change in stock ownership (see § 36.3121(l)(3) -1(b)) with respect to all foreign corporations named in the agreement, including any amendment thereof, a new agreement may be entered into by the domestic corporation, as provided in § 36.3121(l)(1) -1, with respect to any foreign corporation which is a foreign subsidiary of the domestic corporation.(b)Partial termination of agreement.(1) If the effective period of an agreement entered into by a domestic corporation as provided in § 36.3121(l)(1) -1 is terminated by the domestic corporation, pursuant to § 36.3121(l)(3) -1(a), with respect to one or more foreign subsidiaries named in the agreement, including any amendment thereof, the period for which the agreement is in effect will continue with respect to any other foreign subsidiary or subsidiaries named in the agreement (or amendment). However, the agreement may not thereafter be amended to include any foreign subsidiary with respect to which the effective period of the agreement has been terminated.(2) If the effective period of an agreement entered into by a domestic corporation as provided in § 36.3121(l)(1) -1 is terminated automatically by reason of a change in stock ownership (see § 36.3121(l)(3) -1(b)) with respect to a foreign corporation which has ceased to be a foreign subsidiary of the domestic corporation, but the period for which the agreement is in effect continues with respect to one or more other foreign subsidiaries, the agreement may not thereafter be amended to include such foreign corporation even though the foreign corporation may again become a foreign subsidiary of the domestic corporation. 26 C.F.R. §36.3121(l)(5)-1